News & Analysis as of

Banks Banking Examinations

Goodwin

Dos and Don'ts of Interacting with Bank Regulators

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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

GeoDataVision

How to Figure Out How the New CRA Affects Your Bank

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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

Sheppard Mullin Richter & Hampton LLP

OIG Issues Audit Memorandum to FDIC’s Regional Service Provider Examination Program, Impacts Fintechs

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

GeoDataVision

New CRA Rule is a Disaster for Banks Part II: Key Regulator says Goal was “to raise the bar for CRA performance”

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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

GeoDataVision

New CRA Rule is a Disaster for Banks: Part I – And the Numbers Prove it!

GeoDataVision on

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

Ballard Spahr LLP

FDIC launches new tool for examination planning

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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

Cadwalader, Wickersham & Taft LLP

OCC Releases Bank Supervision Operating Plan

Last week, just after we went to press, the Office of the Comptroller of the Currency (“OCC”) released its Bank Supervision Operating Plan for Fiscal Year 2023.  The Operating Plan sets out the OCC’s supervision...more

Nutter McClennen & Fish LLP

Nutter Bank Report: January 2022

Federal Reserve Considers Merits of Creating a U.S. Dollar Digital Currency The Federal Reserve has published a discussion paper that examines the pros and cons associated with the creation of a U.S. central bank digital...more

K2 Integrity

Avoiding Missteps in Virtual Exams - Why communication and documentation are key for banks

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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

Sheppard Mullin Richter & Hampton LLP

Fed’s Vice Chair for Supervision Proposes a Deregulatory Approach to Limit the Scope of “Matters Requiring Attention” used in Bank...

A January proposal to give banks compliance slack floated by a high-ranking Federal Reserve Board (“FRB”) official has not yet gained the traction its supporters had hoped for. In remarks before the American Bar Association...more

Troutman Pepper

Managing Your Next Examination - You Got This

Troutman Pepper on

Bank examinations, holding company inspections and other “supervisory events” can be a source of anxiety and dread for those who work in the banking industry. Originally published in ABA Bank Compliance - March/April 2020....more

Nutter McClennen & Fish LLP

Nutter Bank Report, December 2018

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

A&O Shearman

US Federal Reserve Board, OCC and FDIC Expand 18-Month Examination Cycle for Small Banks and Branches and Agencies of Foreign...

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The U.S. Board of Governors of the Federal Reserve System, U.S. Office of the Comptroller of the Currency and U.S. Federal Deposit Insurance Corporation jointly issued an interim final rule and request for comment to expand...more

Vedder Price

Wells Fargo’s CAMELS Rating Leaked

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The Wall Street Journal recently reported that the management component of the CAMELS rating for Wells Fargo Bank, NA had been downgraded to a “3” during 2017. A “3” rating of management means that the capabilities of...more

WilmerHale

FinCEN Proposes AML Requirements for Registered Investment Advisers

WilmerHale on

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

Troutman Pepper

Observation 2.0: The Anti-Evasion Provision of the Volcker Rule

Troutman Pepper on

Overview This Client Alert continues Pepper’s observations on the Volcker Rule. Critical attention should be paid to the Volcker Rule’s anti-evasion provision, a powerful tool granted by Congress to the regulatory agencies to...more

King & Spalding

The New York State Department Of Financial Services (“DFS”) Issues Industry Guidance Letter To DFS-Regulated Banks

King & Spalding on

On December 10, the DFS issued an industry guidance letter to all New York DFS-regulated banks announcing new targeted DFS cyber security preparedness assessments. The new cyber security assessments will become part of all...more

K&L Gates LLP

New York Department of Financial Services Unveils “New Cyber Security Examination Process”: Five Key Takeaways

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On December 10, 2014, Superintendent Benjamin Lawsky of the New York Department of Financial Services (the “DFS”) announced a “New Cyber Security Examination Process” (the “New Examination Process”) for New York-chartered and...more

Davis Wright Tremaine LLP

FFIEC Releases Revised BSA/AML Examination Manual

The Federal Financial Institutions Examination Council (FFIEC) has released its revised Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual. The revisions clarify supervisory expectations and incorporate...more

Ballard Spahr LLP

CFPB’s Ombudsman’s Office issues third annual report

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Last week, the CFPB’s Ombudsman’s Office issued its third annual report covering the Office’s activities during fiscal year 2014 (October 1, 2013 through September 30, 2014). The role of the Ombudsman’s Office is to assist in...more

Ballard Spahr LLP

OCC steps up SCRA focus in exams

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As we have been reporting, the CFPB has made the Servicemembers Civil Relief Act (SCRA) a major focus and instructs its examiners to look at SCRA compliance during examinations. The OCC has also stepped up its focus on SCRA...more

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