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OCC Proposes Amendments to its Recovery Planning Guidelines

On June 24, the Office of the Comptroller of the Currency (OCC) announced it is requesting comments on proposed amendments to its recovery planning guidelines. A recovery plan’s purpose is to provide a covered bank with a...more

FinCEN Proposes Loosening Customer Identification Program Requirements

On March 29, the Federal Crimes Enforcement Network (FinCEN), in collaboration with other federal agencies, issued a Notice and Request for Information and Comment (Notice and Request) seeking public comment on its proposal...more

FDIC Proposes Increased Scrutiny of Bank Mergers

Today, a divided Federal Deposit Insurance Corporation’s (FDIC) Board of Directors issued a proposed Statement of Policy (SOP) on bank merger transactions that would create a combined bank with more than $100 billion in...more

OCC Proposes Rulemaking Amending Bank Merger Act Procedures to Eliminate Expedited and Streamlined Review and Add Policy Statement...

On January 29, the Office of the Comptroller of the Currency (OCC) issued a notice of proposed rulemaking regarding its review of business combinations under the Bank Merger Act (BMA). Specifically, the OCC proposed: (i)...more

Proposed Rule Clarifies Role of Supervisory Guidance for Financial Institutions

On October 20, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency, and the Consumer...more

OCC Proposes Bright- Line “True Lender” Rule

On July 20, 2020, the Office of the Comptroller of the Currency (OCC) issued its anticipated notice of proposed rulemaking on how to determine when a national bank or federal savings association (referred to collectively as a...more

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