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
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
Why communication and documentation are key for banks. It goes without saying that a regulatory exam can be stressful for financial institutions even under otherwise “normal” operating conditions. However, add in the...more
Examiners Should Focus on Risk, Not Technical Perfection - On April 15, 2020, the Federal Financial Institutions Examination Council (“FFIEC”) released updates to the Bank Secretary Act/Anti-Money Laundering (“BSA/AML”)...more
Financial Institutions ought to design and evaluate compliance programs to meet BSA/AML requirements and to satisfy Bank Examiner expectations. A Financial Institution’s Compliance Programs must comply with the requirements...more
Last month the Financial Crimes Enforcement Network (FinCEN) and the federal bank regulators issued a Joint Statement aimed at improving transparency into their risk-focused examination and supervision of banks’ compliance...more
FDIC Approves 3-Year Phase-In for Adverse Effects on Capital from CECL - The FDIC has approved a final rule that will provide banks with the option to phase in over a three-year period the day-one adverse effects on...more
Incorporation Solidifies Customer Due Diligence as “Fifth Pillar” to BSA/AML Compliance Program - May 11, 2018 was the much anticipated effective date for the Customer Due Diligence (“CDD”) Requirements for Financial...more
The Nutter Bank Report is a monthly publication of the firm's Banking and Financial Services Group. Headlines - 1. CFTC Issues Relief from Swap Clearing Requirements to Small Holding Companies 2. Federal...more
The Financial Crimes Enforcement Network (FinCEN) has proposed long-expected regulations that would extend anti-money laundering (AML) requirements to federally registered investment advisers (RIA). The August 25, 2015...more