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FDIC and OCC Finalize New Guidelines on Bank Mergers

Yesterday, both the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) finalized new guidelines regarding bank mergers. According to the agencies, these updates aim to enhance...more

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

Director of Division of Corporation Finance Issues Guidance on Disclosure of Cybersecurity Incidents under Form 8-K

On May 21, 2024, Erik Gerding, the director of the Division of Corporation Finance of the Securities and Exchange Commission (SEC), released a statement containing guidance for public companies regarding the disclosure of...more

Implications of the FTC’s Noncompete Ban on Financial Institutions

There has been a great deal of press about the Federal Trade Commission’s (FTC) vote to ban employee non-competition provisions and policies. While the FTC describes the rule as a comprehensive ban, it acknowledges that the...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

Acting Comptroller of the Currency Hints About Possible Operational Resilience Regulations

On March 12, at the Institute of International Bankers Annual Washington Conference, Acting Comptroller of the Currency Michael J. Hsu discussed the importance of operational resilience in the banking sector and hinted that...more

Breaking: Community Reinvestment Act Final Rule Published

As discussed here, on October 24, the Federal Reserve Board, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency finally issued their long-awaited final rule modernizing how they...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

Acting Comptroller of the Currency Discusses Potential Short-Term Liquidity Rule at Law School Event

On January 18, at an event hosted by Columbia University Law School, Acting Comptroller of the Currency Michael J. Hsu discussed liquidity risk at banks and described potential “targeted regulatory enhancements” that would...more

OCC Announces Adjusted Maximum Civil Monetary Penalties for 2024

On January 8, the Office of the Comptroller of the Currency (OCC) announced adjustments to the maximum amount of each civil money penalty (CMP) within its jurisdiction. The 2015 Adjustment Act requires federal agencies with...more

Big Tech in the CFPB’s Crosshairs: Bureau Proposes to Supervise Larger Technology Companies Offering Digital Wallets and Payment...

On November 7, the Consumer Financial Protection Bureau (CFPB) issued a proposed rule with request for public comment to amend existing regulations defining “larger participants” the CFPB supervises by adding a new section to...more

Lenders Take Note: Federal Banking Agencies Issue Long-Awaited Community Reinvestment Act Final Rule

On October 24, the Federal Reserve Board (Fed), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the agencies) finally issued their long-awaited final...more

FFIEC Updates Bank Secrecy Act/Anti-Money Laundering Examination Manual

On August 2, the Federal Financial Institutions Examination Council (FFIEC) announced updates to certain sections and examination procedures in the FFIEC Bank Secrecy Act/Anti-Money Laundering Examination Manual (Manual). The...more

Federal Agencies Issue Proposed Rulemaking Revising Capital Requirements for Large Banks

On July 27, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (collectively, the agencies) issued a joint notice of proposed...more

OCC Senior Deputy Comptroller for Large Bank Supervision Provides Insight on Impact to Community Banks of the OCC’s Principles for...

On July 18, Office of the Comptroller of the Currency (OCC) Senior Deputy Comptroller for Large Bank Supervision Greg Coleman testified on OCC supervision of climate-related financial risks before the U.S. House of...more

Federal Agencies Issue Joint Policy Statement on Commercial Loan Workouts

On June 29, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, and the National Credit Union Administration (collectively, the agencies)...more

At Brookings Event, DOJ Official Signals Heightened Scrutiny for Bank Mergers

At a Brookings Institution event on June 20, Assistant Attorney General Jonathan Kanter, a top antitrust official for the U.S. Justice Department (DOJ or Department), announced that the Department will reassess its approach...more

OCC Targets Large Banks with Persistent Weaknesses

On May 25, the Office of the Comptroller of the Currency (OCC) announced that it has revised its manual on bank enforcement actions to specifically address banks that exhibit or fail to correct persistent weaknesses. The...more

FDIC Chairman Addresses Deposit Insurance Misrepresentation at National Bank Conference

On May 23, Chairman Martin J. Gruenberg of the Federal Deposit Insurance Corporation (FDIC) delivered remarks at the Cities for Financial Empowerment Fund 2023 Bank On National Conference. One of the focuses of the Chairman’s...more

FDIC Proposes Special Assessments to Recover Cost of Protecting Uninsured Depositors Amidst Bank Closures

Today, the Federal Deposit Insurance Corporation (FDIC) published a notice of proposed rulemaking that would impose special assessments to recover losses to the Deposit Insurance Fund (DIF) arising from the FDIC’s protection...more

FDIC Recommends Deposit Insurance Reforms to Better Protect Businesses

On May 1, the Federal Deposit Insurance Corporation (FDIC) released a report titled Options for Deposit Insurance Reforms, which outlines three options to reform the nation's deposit insurance system. The three options...more

FDIC Vice Chair Opines on Regulatory Response to Recent Bank Failures

On April 12, at a roundtable discussion hosted by the Bipartisan Policy Center Federal Deposit Insurance Corporation (FDIC) Vice Chair Travis Hill opined that the following potential regulatory responses to the failure of...more

Federal Agencies Take Unprecedented Action to Strengthen Public Confidence in Banking System

On March 10, the California Department of Financial Protection and Innovation closed Silicon Valley Bank and appointed the Federal Deposit Insurance Corporation (FDIC) as its receiver. Silicon Valley Bank had 17 branches in...more

DOJ’s Combatting Redlining Initiative Continues With $9 Million Settlement With Park National Bank

On February 28, the U.S. Department of Justice (DOJ) announced its sixth redlining settlement under its Combatting Redlining Initiative. This most recent case involves an agreement between the DOJ and Ohio-based Park National...more

FDIC Proposes to Modernize Official Sign and Advertising Requirements for Insured Depository Institutions

On December 13, the Federal Deposit Insurance Corporation (FDIC) released a proposal to modernize the rules governing use of the official FDIC sign and insured depository Institutions’ (IDIs) advertising statements — the...more

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