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Focus on Fintech: Federal Banking Regulators Adopt Final Rule for Reporting of Certain Computer-Security Incidents

On November 23, 2021, the OCC, Federal Reserve Board, and FDIC issued a joint final rule that requires banking organizations and their service providers to report certain computer-security incidents. A computer-security...more

Federal Banking Regulators Shine Light Again on Third-Party Risk Management

Federal banking regulators have again demonstrated their focus on bank oversight and management of risk from third party relationships through a series of guidance and proposed guidance published in the third quarter of 2021....more

Biden Administration Makes Progress on Appointing Lead Financial Services Regulators

In September, Biden nominated Saule Omarova to head up the OCC as Comptroller of the Currency after a months’ long candidate search. Earlier this year, potential nominees for the Comptroller included Michael Barr, who...more

Second Circuit grapples with standing in case challenging OCC’s fintech charter authority

On March 9, a three-judge panel of the Second Circuit heard oral argument on the question of whether the OCC can legally issue national bank charters to non-depository financial technology (fintech) firms. The case is...more

Southern District of New York rules against OCC fintech charter

On October 23, the District Court for the Southern District of New York (SDNY) issued a final judgment setting aside in relevant part the regulation on which the Office of the Comptroller of the Currency (OCC) based its...more

Interagency Guidance: CIP Requirements Apply to Certain Prepaid Cards

On March 21, the Board of Governors of the Federal Reserve, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency (OCC), and the U.S. Department of...more

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