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OCC and FDIC Propose Rules to Confirm “Valid-When-Made” Doctrine

Over the last two days, the Office of the Comptroller of the Currency (“OCC”) and the Federal Deposit Insurance Corporation (“FDIC”) (together, the “Agencies”) each issued a proposed rule (collectively, the “Proposed Rules”)...more

11/25/2019  /  FDIC , Lenders , OCC , Proposed Rules

OCC and FDIC Ease “Volcker Rule” Restrictions on Proprietary Trading: SEC, CFTC, and Federal Reserve Expected to Follow Suit

On August 20, 2019, the Board of Directors of the Federal Deposit Insurance Corporation (“FDIC”) and the Office of the Comptroller of the Currency (“OCC”) approved amendments to regulations implementing Section 13 of the Bank...more

Costly Thy Habit As Thy Purse Can Buy: Implications of the Proposed HVADC Rules for Borrowers and Lenders of Acquisition,...

On September 27, 2017, the Office of Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (the “Agencies”) released a joint Notice of Proposed...more

OCC Explores Special Purpose National Bank Charter for Fintech Companies

On December 2, 2016, the Office of the Comptroller of the Currency (“OCC”) announced its plans to move forward with a proposal to consider applications from financial technology (“fintech”) companies to receive charters as...more

Bridging the Great Divide: Collaboration Considerations for Banks and Marketplace Lenders

Marketplace lending has grown dramatically over the last several years, but it still remains a nascent industry. As it continues to expand its reach, players in the industry and the traditional banking/investment sector are...more

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