News & Analysis as of

Comptroller Office of the Comptroller of the Currency

Ballard Spahr LLP

OCC to review its preemption interpretations in light of Supreme Court opinion and state debanking laws

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On July 17, Acting Comptroller of the Currency Michael Hsu delivered prepared remarks before the Exchequer Club entitled “Size, Complexity, and Polarization in Banking.”...more

Ballard Spahr LLP

Former Comptrollers of the Currency file amicus brief in SCOTUS case disagreeing with Justice Dept. on scope of national bank...

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The scope of national bank preemption is currently before the U.S. Supreme Court in Cantero v. Bank of America, N.A. A New York statute requires the payment of interest on mortgage escrow accounts and the question before the...more

Troutman Pepper

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

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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

K2 Integrity

Crypto in a Time of Uncertainty

K2 Integrity on

On 07 June 2023, K2 Integrity hosted a webinar on the state of cryptocurrency and digital assets in a rapidly evolving regulatory landscape. A discussion was held with Bryan Stirewalt, senior managing director at K2...more

Nutter McClennen & Fish LLP

Nutter Bank Report: May 2023

FDIC Announces Special Assessments to Recover Losses from Recent Bank Failures The FDIC has issued a proposed rule that would impose special assessments to recover the loss to the Deposit Insurance Fund (Fund) arising from...more

Orrick, Herrington & Sutcliffe LLP

Hsu presses for global supervision of crypto

On March 6, acting Comptroller of the Currency Michael J. Hsu commented that the collapse of a major cryptocurrency exchange has underscored a need for consolidated supervision of global cryptocurrency firms. Speaking before...more

Orrick, Herrington & Sutcliffe LLP

OCC revises guidance on change in bank control

On February 16, the OCC released an updated version of the “Change in Bank Control” booklet of the Comptroller’s Licensing Manual. According to OCC Bulletin 2023-7, the revised licensing booklet—which outlines OCC policies...more

Orrick, Herrington & Sutcliffe LLP

OCC revises guidance on branch closings

On February 7, the OCC released an updated version of the “Branch Closings” booklet of the Comptroller’s Licensing Manual. According to OCC Bulletin 2023-6, the revised licensing booklet, which outlines policies and...more

Latham & Watkins LLP

Acting Comptroller Confronts “Too Big to Manage” Issue

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The Acting Comptroller of the OCC discussed the limits of large bank manageability and the steps that regulators can take to address the risks posed by size and complexity. On January 17, 2023, Acting Comptroller of the...more

Orrick, Herrington & Sutcliffe LLP

OCC revises Comptroller’s Licensing Manual

On January 19, the OCC announced an updated version of the “Branches and Relocations” booklet of the Comptroller’s Licensing Manual. According to Bulletin 2023-04, the revised booklet replaces booklet of the same title issued...more

Ballard Spahr LLP

Acting Comptroller discusses crypto risks, including use of bank-like terminology

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In remarks at the DC Fintech Week conference on October 11, 2022 and in a keynote address later the same day at a roundtable conducted by the Harvard Law School Program on International Financial Systems, Acting Comptroller...more

Sheppard Mullin Richter & Hampton LLP

OCC Highlights Focus on Crypto and Bank-FinTech Partnerships, Anticipates Stricter Scrutiny Going Forward

On September 7, Acting Comptroller of the Currency, Michael Hsu, discussed the long-term threats to trust in banking in remarks at the TCH + BPI Annual Conference. Hsu provided updates on key priorities at the OCC, including...more

Paul Hastings LLP

Daily Financial Regulation Update -- Wednesday, August 3, 2022

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August 2, 2022- The U.S. Senate Committee on Banking, Housing, and Urban Affairs held a hearing entitled, "'The Rent Eats First': How Renters and Communities are Impacted by Today's Housing Market."...more

Moore & Van Allen PLLC

Acting Comptroller Hsu Suggests a Potential Path Forward to Address Identified Gaps in the Regulatory Resolution Framework for...

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In the fourteen years since the 2008 financial crisis, significant actions have been taken by Federal banking agencies to make the largest financial institutions more resilient and less likely to fail and to require planning...more

Sheppard Mullin Richter & Hampton LLP

Acting Comptroller Discusses Architecture of Stablecoins

On April 8, the acting comptroller of the currency, Michael J. Hsu, discussed many aspects of stablecoins (we previously discussed the President’s Working Group report on stablecoins and Hsu’s comments...). In his speech at...more

Goodwin

Acting Comptroller Discusses Crypto-Assets and Regulation

Goodwin on

In This Issue. Acting Comptroller of the Currency Michael J. Hsu discussed the importance of regulation in the crypto space; and the Office of the Comptroller of the Currency (OCC) and the Consumer Financial Protection Bureau...more

Sheppard Mullin Richter & Hampton LLP

OCC: Crypto and DeFi Must Avoid Another Financial Crisis

Michael Hsu, the acting chief of the Office of the Comptroller of the Currency, recently addressed his remarks to the Blockchain Association drawing similarities between the current growth of cryptocurrencies and...more

Goodwin

FDIC Seeks Comment on Supervisory Approach to Examinations During Pandemic

Goodwin on

In This Issue. The Federal Deposit Insurance Corporation (FDIC) is seeking information and comment regarding the FDIC’s supervisory approach to examinations during the pandemic; the FDIC’s tech lab, FIDTECH, announced a “tech...more

Goodwin

Tenth Circuit Upholds District Court’s Ruling Finding No Breach of Fiduciary Duties in Section 36(b) Case

Goodwin on

In This Issue. The federal bank regulators published frequently asked questions concerning the London Interbank Offered Rate transition; the Consumer Financial Protection Bureau (CFPB) confirmed an effective date for two...more

McGlinchey Stafford

U.S. House Of Representatives Votes To Override OCC True Lender Rule

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The U.S. House of Representatives on June 24th voted 218 to 208 to repeal the Office of the Comptroller of the Currency’s (OCC) “True Lender” rule under the Congressional Review Act (CRA). As discussed in earlier alerts, the...more

Goodwin

Fed Invites Public Comment on Proposed Changes to Durbin Amendment

Goodwin on

In this Issue. The Board of Governors of the Federal Reserve System (Federal Reserve) invited public comment on proposed changes to Regulation II, better known as the Durbin Amendment, regarding network availability for...more

Morrison & Foerster LLP

Financial Services Report - Spring 2021

Can you say 0 to 60? Not cars, but pretty much everything to do with financial services. A new year, a new administration, and new challenges for providers. Prior CFPB Director Kraninger is long gone. Acting Director Uejio...more

Perkins Coie

Fintech Week in Review - January 2021 #2

Perkins Coie on

California DFPI Begins Operating and Focuses on New Industries January 2021 brings with it a newly named and newly empowered California consumer financial protection agency. Effective January 1, the California Department of...more

UB Greensfelder LLP

LPL AWC Proves, Once Again, That Big Firms Can Buy Their Way Out Of Trouble That Would Kill Small Firms

UB Greensfelder LLP on

LPL may be the biggest BD in the country, with 21,500 reps operating out of almost 13,000 branch offices. Heaven knows how much money it brings in every year, but, goodness, it must be a lot. And good thing, too, given how...more

Morrison & Foerster LLP

OCC Permits National Banks And Federal Savings Associations To Use Independent Node Verification Networks And Stablecoins For...

As part of the Office of the Comptroller of the Currency’s (OCC) declared effort to keep pace with a mounting demand for faster, cheaper, and more efficient payments, and the widespread adoption of new technologies, the...more

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