On September 6, Acting Comptroller of the Currency Michael Hsu warned that fintech and big techs partnerships and their forays into payment and lending could lead to increased risk for the banking industry. “My sense is that...more
On April 7, the Federal Deposit Insurance Corporation (FDIC) released a letter, requiring all FDIC-supervised institutions that intend to engage in, or that are currently engaged in, crypto-related activities to notify its...more
On February 8, a Northern District of California judge ruled on cross motions for summary judgment filed by the states of California, Illinois, and New York (plaintiffs) and the Office of the Comptroller of the Currency and...more
On January 18, the Office of the Comptroller of the Currency (OCC) conditionally approved an application by Social Finance Inc. (SoFi) to acquire Golden Pacific Bank, National Association, so long as the new bank does "not...more
Will 2022 be the year of comprehensive digital asset legislation in the U.S.?...more
Introduction -
On November 18, federal banking agencies issued the long-awaited final rule, establishing data security incident response notification requirements for “banking organizations” and “bank service providers”...more
12/2/2021
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Reporting Requirements
The Office of the Comptroller of the Currency (OCC) issued a proposal to rescind its June 2020 Community Reinvestment Act (CRA) rulemaking and replace it with previous rules jointly adopted by the OCC, the Federal Reserve...more
On October 18, consumer advocate groups and 19 state attorneys general wrote comment letters, urging banking regulators to denounce “rent-a-bank” arrangements between financial institutions and fintechs or other third-party...more
Environmental, social, and governance (ESG) matters have become a focal point for investors and regulators. For financial institutions, and other companies, climate risk has become a key component, and an increasingly...more
In the future, most de novo banks in the United States will be formed by existing payments and nonbank fintech companies that provide financial services, or groups of players in those industries that want to form a payments...more
The Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), and the Department of the Treasury Office of the Comptroller of the Currency (OCC) have published proposed...more
On June 24, the House of Representatives, like the Senate on May 11, voted to overturn the Office of the Comptroller of Currency’s (OCC) “True Lender Rule” that was finalized in October 2020. The Senate initiated the process...more
On April 9, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies), in consultation with the Financial...more
The trend of fintech companies seeking or acquiring U.S. banking licenses continues to build momentum, furthering the convergence of fintech and banking. More fintech companies are applying and being approved for banking...more
In a final act of his tenure, Brian Brooks, the acting Comptroller of the Currency (OCC) on January 14 finalized a rule to ensure “fair access to banking services provided by large national banks, federal savings...more
On November 20, the Office of the Comptroller of Currency (OCC) proposed a rule aimed at ensuring fair access to bank services, capital, and credit. Citing pushes from across the political spectrum to “de-bank” industries...more
On November 17, President Trump nominated current Acting Director of the Office of the Comptroller of the Currency Brian Brooks to a full five-year term as the comptroller of the currency. Though the nomination occurs during...more
Why It Matters -
On November 9, the Office of the Comptroller of the Currency’s (OCC) National Risk Committee issued its Semiannual Risk Perspective for fall 2020 (Report), providing a review of issues facing banks and...more
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
On October 27, the Office of the Comptroller of the Currency (OCC) issued its final rule on how to determine when a national bank or federal savings association (referred to collectively as a national bank) is the “true...more
In the first case decided on the issue of whether Madden v. Midland Funding, LLC is applicable to a credit card securitization, the United States District Court for the Western District of New York, on September 21, 2020,...more
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