News & Analysis as of

Depository Institutions Risk Management

Stinson LLP

CFPB and OCC Signal Strategic Shifts in Supervision and Enforcement

Stinson LLP on

In April 2025, both the Consumer Financial Protection Bureau (CFPB) and the Office of the Comptroller of the Currency (OCC) announced significant changes to their supervisory and enforcement approaches, signaling a shift in...more

Troutman Pepper Locke

OCC Ceases Examinations for Reputation Risk Following Legislative Push

Troutman Pepper Locke on

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

WilmerHale

Why Depository Institutions, with or Without Affiliated Securities Firms, can and should Manage Employee Use of Personal Devices...

WilmerHale on

The purpose of this paper is to show how the failure to monitor for and prevent off-channel communications poses risk to traditional depository institutions that are not subject to the jurisdiction of securities-law...more

Orrick, Herrington & Sutcliffe LLP

FDIC OIG reports on readiness to resolve large regional banks

Recently, the FDIC Office of Inspector General released a report entitled, “FDIC Readiness to Resolve Large Regional Banks,” which evaluated the FDIC’s preparedness to resolve large regional bank failures under the Federal...more

Hudson Cook, LLP

Pay Now or Pay Later, But Paying Later May Cost a Whole Lot More

Hudson Cook, LLP on

The Consumer Financial Protection Bureau has long required that an institution within the scope of its supervision or enforcement authority, including both depository institutions like banks and non-depository consumer...more

WilmerHale

Interagency Issuances on Bank-Fintech Partnerships Highlights Risks, Opportunities, Importance of Industry Participant Engagement

WilmerHale on

The recent bank regulatory Joint Statement and request for information (RFI) on third-party deposit relationships and bank-fintech partnerships emphasize afresh regulators’ long-standing concern with financial institutions’...more

Pillsbury - Global Sourcing Practice

Operational Resilience Requirements May Be Coming for Large U.S. Banks Soon

On March 12, 2024, Acting Comptroller of the Currency Michael Hsu indicated in a speech that regulations may soon be forthcoming that would be designed to bolster larger depository institutions’ ability to withstand...more

Troutman Pepper Locke

Nacha Approves New Rules to Combat Credit-Push Fraud

Troutman Pepper Locke on

On March 18, Nacha, the organization that governs the ACH network, announced that its members approved a new set of rules aimed at reducing the incidence of frauds, such as business email compromise (BEC), that exploit...more

Nutter McClennen & Fish LLP

Nutter Bank Report: February 2024

The U.S. Department of Justice (DOJ) and state authorities have agreed to a consent order with a large national bank to resolve allegations that the bank engaged in a pattern or practice of lending discrimination by affecting...more

Stikeman Elliott LLP

AMF Publishes Draft Climate Risk Management Guideline

Stikeman Elliott LLP on

On November 30, 2023, the Autorité des marchés financiers (AMF), the organization that oversees Québec’s financial industry, published a draft Climate Risk Management Guideline (the Guideline) which will apply to licensed...more

Foodman CPAs & Advisors

La Revisión De Riesgos De La FDIC 2023 Agrega El Cripto

El 14/08/23 se publicó la Revisión de Riesgos de la FDIC 2023. El informe “FDIC Risk Review 2023” resume las condiciones de la economía, los mercados financieros y la industria bancaria de los EE. UU. El informe proporciona...more

Foodman CPAs & Advisors

FDIC Risk Review 2023 Adds Crypto

On 8/14/23, the FDIC Risk Review 2023 was published. The FDIC Risk Review 2023 report summarizes conditions in the U.S. economy, financial markets, and banking industry. The report provides a comprehensive summary of key...more

Cadwalader, Wickersham & Taft LLP

FDIC Issues Bank Failure Post Mortem Report

Recently, the Federal Deposit Insurance Corporation (“FDIC”) issued a report from its Chief Risk Officer entitled FDIC’s Supervision of First Republic Bank. The FDIC was First Republic Bank’s primary federal banking agency,...more

Troutman Pepper Locke

Federal Agencies Issue Joint Guidance on Contingency Planning for Liquidity Risks

Troutman Pepper Locke on

On July 28, the Board of Governors of the Federal Reserve System (Federal Reserve), Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, and the National Credit Union Administration (NCUA)...more

Miller Nash LLP

TL;DR: The Feds on SVB and Deposit Insurance Reform

Miller Nash LLP on

The Federal Reserve recently published a whopping 118-page review of the failure of Silicon Valley Bank (SVB), and three days later the FDIC published a 75-page report outlining several ideas to reform our deposit insurance...more

Wyrick Robbins Yates & Ponton LLP

The Federal Reserve and FDIC’s Reports on the Silicon Valley Bank and Signature Bank Failures – Lessons to be Learned

On April 28, 2023, the Board of Governors of the Federal Reserve System (“Federal Reserve”) and the Federal Deposit Insurance Corporation (“FDIC”) each released reports detailing the respective agency’s supervision history...more

Goodwin

Bank Officer and Director Enforcement Exposures In the Wake of Silicon Valley Bank

Goodwin on

The recent and sudden failures of Silicon Valley Bank and Signature Bank, and the threat of other bank failures, have led to intense public focus on what caused these banks to run into trouble, who is to blame, and what...more

Hogan Lovells

Learning from Silicon Valley Bank - Never let a good crisis go to waste – so how could you use recent events in California to take...

Hogan Lovells on

Many lessons will be learned from the failure of Silicon Valley Bank last weekend. The full story is unlikely to emerge for some time, but commentators have quickly reached a consensus on the likely causes. The central...more

Goodwin

How should I be thinking about my cash management options in light of recent events?

Goodwin on

Consider multiple bank relationships. Consider putting in place one or more additional banking relationships. Consider banking with an institution that maintains excess deposit insurance. Massachusetts-chartered savings...more

Foley Hoag LLP

Silicon Valley Bank: Preparing for Monday

Foley Hoag LLP on

Just before noon on Friday March 10, 2023, Silicon Valley Bank (SVB) was shut down by the California Department of Financial Protection and Innovation and the Federal Deposit Insurance Corporation (FDIC) was named as the...more

Nutter McClennen & Fish LLP

Nutter Bank Report: July 2022

Headlines - ..New Federal Guidance Issued on Customer Due Diligence and Risk Management ..Fed Proposes Rule to Mandate LIBOR-Replacement Benchmark Rates in Contracts ..CFPB Clarifies Permissible Purposes for Furnishing,...more

Goodwin

OCC Seeks Feedback on Principles for Climate-Related Financial Risk Management

Goodwin on

In this Issue. The Office of the Comptroller of the Currency (OCC) is seeking feedback on principles for climate-related financial risk management for large banks; the Department of Justice’s Antitrust Division is seeking...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

OCC Reconsiders Controversial Revisions to CRA Rules

Goodwin on

In This Issue. The Office of the Comptroller of the Currency (OCC) announced that it will reconsider its controversial June 2020 final rule revising its Community Reinvestment Act (CRA) rules, and published its Semiannual...more

Nutter McClennen & Fish LLP

Fintech in Brief: FDIC Solicits Information on Digital Assets

On May 17, 2021, the Federal Deposit Insurance Corporation (the “FDIC”) issued a Request for Information and Comment (the “RFI”) on Digital Assets. The FDIC is interested in getting input from all interested parties on the...more

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