News & Analysis as of

Office of the Comptroller of the Currency Policies and Procedures

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - February 2024 - 3

Editor's Note: The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically...more

Husch Blackwell LLP

FFIEC Issues Statement on Examination Principles Related to Valuation Discrimination and Bias in Residential Lending

Husch Blackwell LLP on

On February 12, 2024, the Federal Financial Institutions Examination Council (FFIEC) issued a statement of principles that relate to valuation discrimination and bias for its member entities to consider in preparation for...more

Latham & Watkins LLP

OCC, FRB, and FDIC Finalize Joint Principles for Climate-Related Financial Risk Management

Latham & Watkins LLP on

Guidance for the largest US financial institutions is intended to promote climate risk management consistent with general safety and soundness practices. On October 30, 2023, the three US federal bank regulatory agencies...more

Holland & Knight LLP

Agency Guidelines Confirm That Climate-Related Financial Risk Is Real

Holland & Knight LLP on

The U.S. Department of the Treasury's Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System (Board) and the Federal Deposit Insurance Corp. (FDIC) (collectively, the Agencies) on...more

Snell & Wilmer

Climate-Related Financial Risk Management Final Interagency Guidance Rules Issued – Now What’s Next?

Snell & Wilmer on

On October 24, 2023, the Federal Reserve (Fed), Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller of the Currency (OCC) issued the joint agency climate-related financial risk management guidance for...more

Amundsen Davis LLC

Insights from the OCC Semiannual Risk Perspective

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On June 14, 2023, the Office of the Comptroller of the Currency (OCC) published its Semiannual Risk Perspective which identifies key issues facing the federal banking system. This highly anticipated report comes in the wake...more

Goodwin

Agencies Issue Final Guidance on Third-Party Risk Management

Goodwin on

Agencies Issue Final Guidance on Third-Party Risk Management - On June 6, the Federal Reserve, FDIC, and OCC issued final joint guidance (the Guidance) pertaining to banking organizations’ risk management of third-party...more

Cadwalader, Wickersham & Taft LLP

OCC Issues Updated Enforcement Action Policies and Procedures Manual

The Office of the Comptroller of the Currency (“OCC”) issued an updated Policies and Procedures Manual (PPM 5310-3) on Bank Enforcement Actions and Related Matters last week. The PPM is updated from the 2018 issuance. The...more

J.S. Held

Off-Channel Communications: How Financial Services Organizations Can Address Regulators’ Latest Target

J.S. Held on

As a number of recent headlines demonstrate, the U.S. Securities and Exchange Commission (SEC) and other regulators have fined and penalized employers and employees in the financial services industry for non-compliance with...more

Sheppard Mullin Richter & Hampton LLP

OCC Revises Policies and Procedures for Civil Money Penalties

On November 29, the OCC released a revised Policies and Procedures Manual relating to the assessment of civil money penalties (“CMP Matrix”), which will be effective as of January 1, 2023. The CMP Matrix is a reference guide...more

Goodwin

SEC Proposes Changes to Private Fund Regulation

Goodwin on

In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed changes to private fund regulation; the Office of the Comptroller of the Currency (OCC) succeeded in validating its “valid-when-made” rulemaking; the...more

Goodwin

SEC Proposes New Round of Money Market Fund Reforms

Goodwin on

In This Issue. The U.S. Securities and Exchange Commission (SEC) voted to propose money market fund reforms; the SEC also proposed amendments to Rule 10b5-1 trading plans and to modernize and improve share repurchase...more

Goodwin

SEC Publishes Sample Climate Change Comment Letter

Goodwin on

In This Issue. The U.S. Securities and Exchange Commission (SEC) published a sample comment letter on climate change disclosures; the Financial Industry Regulatory Authority (FINRA) is conducting a review of brokerage firm...more

Goodwin

Agencies Publish Notice and Request for Comment on Proposed Interagency Guidance on Third-Party Relationships

Goodwin on

In This Issue. The federal bank regulatory agencies requested public comment on proposed guidance designed to help banking organizations manage risks associated with third-party relationships; the Office of the Comptroller of...more

Bradley Arant Boult Cummings LLP

Things That Go Bump in the Night: Top 10 Considerations to Watch Out for in the Small Dollar Lending Industry

Nothing is scarier than 2020! But Bradley has you covered with a treat. Here are a list of “Things That Go Bump in the Night: Top 10 Considerations to Watch Out for in the Small Dollar Lending Industry.” Wishing you a...more

A&O Shearman

Options Clearing Corporation Enters Into Settlements With SEC And CFTC Over Risk Management Policies

A&O Shearman on

On September 4, 2019, the Securities and Exchange Commission (“SEC”) and the Commodity Futures Trading Commission (“CFTC”) announced they had entered into settlements with Options Clearing Corporation (“OCC”) regarding its...more

Katten Muchin Rosenman LLP

Bridging The Week - September 2019

A clearing organization for futures and securities was sanctioned US $20 million in aggregate by the Commodity Futures Trading Commission and the Securities and Exchange Commission for allegedly not having and following...more

Orrick - Finance 20/20

OCC Extends Dodd-Frank Act Stress Test Requirements Through November 25

Orrick - Finance 20/20 on

The Office of the Comptroller of the Currency (OCC) announced that the deadline to comply with Dodd-Frank Act Stress Test (DFAST) requirements will be extended to November 25, and thereafter will be discontinued. ...more

Ballard Spahr LLP

OCC bulletin allows CRA downgrades for evidence of discriminatory credit practices

Ballard Spahr LLP on

A new bulletin issued by the Office of the Comptroller of the Currency (OCC), Bulletin 2018-23, makes slight, but significant, changes to OCC policy regarding when evidence of illegal or discriminatory credit practices could...more

Ballard Spahr LLP

OCC small-dollar lending bulletin: one step forward but one step back?

Ballard Spahr LLP on

The OCC has issued a bulletin (2018-14) setting forth core lending principles and policies and practices for short-term, small-dollar installment lending by national banks, federal savings banks, and federal branches and...more

A&O Shearman

US Government Accountability Office Releases Report Regarding US Federal Financial Institution Regulator Compliance with the...

A&O Shearman on

The US Government Accountability Office released a report that details the compliance of six US federal financial institution regulators (the US Board of Governors of the Federal Reserve System, the US Office of the...more

Ruder Ware

OCC Updates Guidance on Business Combinations

Ruder Ware on

The Office of the Comptroller of the Currency (“OCC”) has recently updated its “Business Combinations” booklet, which is part of the Comptroller’s Licensing Manual. The revised booklet replaces the prior version, which was...more

Ballard Spahr LLP

OCC Revises its Enforcement Policies and Procedures Manual

Ballard Spahr LLP on

In an update to its Policies and Procedures Manual (PPM), the Office of the Comptroller of the Currency (OCC) has revised PPM 5310-3, “Enforcement Action Policy,” dated September 9, 2011. The PPM sets forth the OCC’s policies...more

Ballard Spahr LLP

OCC establishes framework for evaluating applications from banks with less than satisfactory CRA rating

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In a new Policies and Procedures Manual (PPM) issuance (PPM 6300-2), the OCC establishes its framework for evaluating certain types of licensing applications when the applicant bank has an overall Community Reinvestment Act...more

Ballard Spahr LLP

OCC issues risk management principles for new activities

Ballard Spahr LLP on

On October 20, 2017, the Office of the Comptroller of the Currency (OCC) issued Bulletin 2017-43 (the “Bulletin”) outlining principles that OCC-supervised banks should follow to prudently manage the risks associated with...more

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