On December 1, 2025, the Federal Reserve released its semiannual Supervision and Regulation Report describing a broad reduction in outstanding supervisory findings across institutions of all sizes. The report indicates...more
On November 21, the CFPB announced changes to how its Supervision Division will conduct examinations, including a new “Humility Pledge” that examiners must read to supervised entities at the start of each review. The Bureau...more
The OCC has announced changes to Bank Secrecy Act/Anti-Money Laundering (BSA/AML) examination procedures and data collection requirements applicable to community banks to reduce regulatory burdens. The policy changes are...more
The FDIC has announced that its Consumer Compliance Examination Manual has been revised to reflect an updated examination schedule for financial institutions. As a result, agency consumer compliance examinations and Community...more
Over this past year, the Federal Reserve, OCC, and FDIC have announced a slate of proposals and actions to reform supervision, reduce compliance costs, and refocus attention on matters that may have a material financial...more
As previously covered by InfoBytes, the NCUA announced last month that, effective immediately, reputation risk would no longer factor into its examinations and supervisory process. The agency is now attempting to codify its...more
The FDIC and the OCC have issued a Notice of Proposed Rulemaking that seeks to establish a standard definition for what constitutes an “unsafe or unsound practice.” ...more
On October 6, the Office of the Comptroller of the Currency (OCC) announced a series of significant actions aimed at reducing the regulatory burden on community banks. These initiatives are part of the OCC’s ongoing efforts...more
On March 20, the Office of the Comptroller of the Currency (OCC) announced that it will no longer examine its regulated institutions for reputation risk. According to the OCC’s “Categories of Risk,” reputation risk is the...more
On February 20, 2025, the Office of the Comptroller of the Currency (“OCC”) announced that they had entered into a formal agreement with Patriot Bank, National Association (“Patriot Bank”), following a comprehensive...more
Alex Barrage, a partner in Troutman Pepper Locke’s Financial Services Industry Group, was quoted in the February 6, 2025 Banking Dive article, “Concerns Mount Over FDIC Staffing Challenges.”...more
Until recently, the most popular topic of discussion in the financial services world has been the outcome of the Supreme Court case CFPB v. Community Financial Services Association of America, regarding the constitutionality...more
Supervision is a daily fact of life for bank boards and management. Below, we offer strategies for how both board members and members of management can ensure that the supervisory process goes as smoothly as possible....more
As 2024 gets off the ground, federal regulators are continuing their focus on fair lending issues. In February, the Federal Financial Institutions Examination Council (FFIEC) released a statement on examination principles...more
A recent bipartisan bill, if enacted, would particularly benefit small lenders and bank/fintech partnerships by promoting transparency, appellate rights and examiner accountability. On Dec. 14, 2023, a bipartisan group of...more
I’ve written at least a dozen articles about the dramatic impact the new CRA is going to have on banks. Until now, only about 1.2% of bank CRA examinations end with a failing grade. But, by the estimates of the regulators, if...more
On September 27, 2023, the Office of the Comptroller of the Currency (OCC) issued Version 2.0 of the Lease Financing booklet of the OCC’s Comptroller Handbook, which replaced Version 1.0 published in August 2014 and updated...more
A recent bipartisan bill, if enacted, would particularly benefit small lenders and bank-fintech partnerships by promoting transparency, appellate rights, and examiner accountability. On December 14, 2023, a bipartisan...more
On December 21, the Office of Inspector General (OIG) of the FDIC issued its audit memorandum on the FDIC’s Regional Service Provider (RSP) Examination Program. The OIG’s objective was to assess the effectiveness of the...more
In my previous email I explained the devastating impact of the new CRA Rule on the percentage of banks receiving a less than satisfactory CRA Performance Rating. The data in Table 32 within the new Rule demonstrate that if...more
With all the news stories circulating about the new CRA Rule, it's surprising that not one article has addressed the topic that should be the biggest story of all - the catastrophic implications for banks!...more
Earlier this month, the CFPB filed a notice with the Texas federal district court that it is appealing to the Fifth Circuit the district court’s order granting summary judgment to a group of trade associations in their...more
The Federal Deposit Insurance Corporation has announced that it is launching a new Banker Engagement Site (BES) this month through FDICconnect to serve as the primary tool for exchanging examination planning and other...more
In an unusual move, Laura Akahoshi, former Rabobank (the “Bank”) Chief Compliance Officer (“CCO”), filed on July 6, 2023 an opposition to the Office of the Comptroller of the Currency’s (“OCC”) dismissal of its own...more
Asserting that irreparable harms to their members “are piling up,” the U.S. Chamber of Commerce and the other plaintiffs have filed a motion for a status conference with the Texas federal district court hearing their lawsuit...more