News & Analysis as of

OCC Requests Comments on Proposed Guidelines Setting Minimum Standards for Risk Governance Framework and Board Oversight of Banks...

The OCC issued proposed guidelines (the “Proposed Guidelines”) that would establish minimum standards for the design and implementation of a risk governance framework (the “Risk Framework”) by national banks, federal savings...more

OCC Seeks to Formalize Risk Governance Expectations of Large Banks

The proposed guidelines demonstrate the Office of the Comptroller of the Currency’s continued emphasis on strong risk management for large banks. ...more

Orrick's Derivatives in Review - January 2014

Industry Groups File Lawsuit Challenging Cross-Border Guidance - On December 4, 2013, the Securities Industry and Financial Markets Association, the International Swaps and Derivatives Association, Inc., and the...more

Federal Reserve Adds to Agency Guidance on Third Party Relationships

On Dec. 5, 2013, the Federal Reserve joined the list of regulatory agencies that have issued guidance on third party relationships. The Fed guidance supplements the FFIEC Outsourcing Technology Services Booklet (June 2004)...more

OCC Releases Annual Assessment Schedule

On December 12, the OCC issued Bulletin 2013-37, which informs all national banks, federal savings associations, and federal branches and agencies of foreign banks of fees and assessments charged by the OCC for calendar year...more

The Volcker Rule: Impact of the Final Rule on Securitization Investors and Sponsors

On December 10, 2013, the Federal Reserve, FDIC, OCC, SEC and CFTC (the “Agencies”) issued the long-awaited final rule (the “Final Rule”) implementing the Volcker Rule. The Volcker Rule generally prohibits banking entities —...more

The Volcker Rule: Impact of the Final Rule on Foreign Banking Organizations

On December 10, 2013, the Federal Reserve, FDIC, OCC, SEC, and CFTC (the “Agencies”) issued the long-awaited final rule (“Final Rule”) construing the Volcker Rule. The Volcker Rule generally prohibits banking entities — a...more

Structured Thoughts -- Volume 4, Issue 14 -- December 2, 2013

In This Issue: Launching an Exempt Structured Products Program in the United States: Issues for Non-U.S. Banks to Consider; “Big-Boy Letters” Revisited: Pharos Decision Upheld by the Sixth Circuit.; SEC Addresses...more

Orrick's Financial Industry Week In Review - July 15, 2013

In This Issue: Financial Industry Developments; Rating Agency Developments; RMBS and Other Securities Litigation; and, European Financial Industry Developments. ...more

Fed Rewrites Section 716 of Dodd-Frank

The Federal Reserve on Wednesday, June 5, issued an interpretation of the so-called “swaps push-out” section of the Dodd-Frank Act that corrects a drafting error that virtually everyone agrees needed to be fixed. The Federal...more

Federal Reserve Board, Illinois Regulator Issue Joint Enforcement Action Against U.S. Subsidiaries Of Foreign Bank, OCC Issues...

On May 17, the Federal Reserve Board released an April 29, 2013 written agreement between the Federal Reserve Board, an Illinois state regulator, a foreign bank, and its U.S. bank holding company subsidiary (the Holding...more

Orrick's Financial Industry Week in Review - January 7, 2013

In This Issue: *Financial Industry Developments - OCC Guidance on Transition Periods under Section 716 of the Dodd-Frank Act - CFTC Reporting of Swap Transactions and Swap Dealer Registration - Department...more

U.S. Law Enforcement Authorities And Regulators Resolve Significant Money Laundering And Sanctions Investigations

On December 11, a major international bank holding company announced agreements with U.S. law enforcement authorities and federal bank regulators to end investigations into alleged inadequate compliance with anti-money...more

Financial Services Legislative And Regulatory Update -- December 17, 2012

In This Issue: Leading the Past Week; Fiscal Cliff; Legislative Branch; Executive Branch; and Upcoming Hearings. Excerpt from Leading the Past Week - Whatever happened in the world of financial services last...more

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