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Office of the Comptroller of the Currency Banking Regulators

Latham & Watkins LLP

Federal Banking Agencies Plan to Rescind Community Reinvestment Act Final Rule

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In light of ongoing litigation and the Trump administration’s new policy approach, federal banking agencies intend to rescind the 2023 CRA final rule and revert to pre-2023 standards....more

Troutman Pepper Locke

The Conference of State Bank Supervisors Pushes Back on STABLE Act

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The Conference of State Bank Supervisors (CSBS), a nationwide organization of state banking and financial regulators from all 50 states, the District of Columbia, and U.S. territories, has raised significant concerns...more

Nutter McClennen & Fish LLP

Nutter Bank Report: March 2025

The federal banking agencies have announced their intent to issue a proposal to rescind the Community Reinvestment Act (CRA) final rule originally issued in October 2023. In their announcement on March 28, the agencies also...more

Cadwalader, Wickersham & Taft LLP

Regulation in Flux, March 2025 - OCC Gives Green Light to National Bank Fintech Business Model

On March 17th, the Office of the Comptroller of the Currency (“OCC”) conditionally approved the application for the newly renamed SmartBiz Bank N.A. (“SmartBiz Bank”) to change its business model in support of its fintech...more

Nutter McClennen & Fish LLP

Nutter Bank Report: February 2025

Amid media reports that the administration may be considering a plan to consolidate the FDIC, the supervisory functions of the Federal Reserve, and the OCC into a single agency, President Trump issued an executive order...more

Troutman Pepper Locke

Treasury Secretary Bessent to Appoint Rodney E. Hood as First Deputy Comptroller of the OCC

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On February 7, Secretary of the Treasury Scott Bessent announced that he will appoint Rodney E. Hood as a Deputy Comptroller and designate him as the First Deputy Comptroller of the Office of the Comptroller of the Currency...more

Polsinelli

Scrutiny on Financial Institutions Compliance Expected to Increase During Trump Administration

Polsinelli on

Key Takeaways:  Federal bank regulators plan for vigorous review of safety and soundness and consumer compliance functions....more

Moore & Van Allen PLLC

Developments in National Bank Act (NBA) Preemption: Illinois’ Interchange Fee Prohibition Act is Held Preempted by the NBA; Ninth...

Moore & Van Allen PLLC on

For followers of developments related to National Bank Act (NBA) preemption and the United States Supreme Court’s related decision in Cantero v. Bank of America, N.A., 602 U.S. 205 (2024), the waning days of 2024 proved...more

Cadwalader, Wickersham & Taft LLP

Banking Regulators’ Request for Information on Bank-Fintech Arrangements

On July 25, 2024, the Fed, the OCC and the FDIC (the “Banking Regulators”) released a “Request for Information on Bank-Fintech Arrangements Involving Banking Products and Services Distributed to Consumers and Businesses” (the...more

Ballard Spahr LLP

Bank Regulators Issue Statement on Third-Party Relationships with Financial Institutions and Publish Request for Information on...

Ballard Spahr LLP on

The federal banking regulators (The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation) issued on July 25 a lengthy joint statement...more

Ballard Spahr LLP

Banking Regulators Seek Comment on Third-Party Relationships with Financial Institutions

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The federal banking regulators are seeking comment to better understand the relationship between financial institutions and third parties that work for them....more

Cadwalader, Wickersham & Taft LLP

Summer Regulatory Round-Up | July 2024

The banking regulators have not yet gone out on vacation, as demonstrated by this grab-bag of announcements, speeches, rules and guidance: Acting Comptroller of the Office of the Comptroller of the Currency (OCC),...more

Goodwin

10 Considerations for Fintechs Partnering with Community Banks

Goodwin on

As banking and technology become more integrated, banks are increasingly partnering with fintechs to expand their customer offerings. The rapid rise of these partnerships has generated questions for both banks and fintechs on...more

Cadwalader, Wickersham & Taft LLP

The U.S. Basel III Endgame Proposal: Update and Thoughts

On September 18, 2023, the U.S. Basel III Endgame proposal was published in the Federal Register. The comment period ended on January 16, 2024, with the banking regulators (the Federal Reserve, the OCC, and the FDIC) having...more

Venable LLP

Crystal Clear: New Guide on Third-Party Risk Management for Community Banks - and Others

Venable LLP on

It is no secret that the Federal Reserve, the FDIC, and the OCC have zeroed in on banks' use of third parties for products, services, and other operations, the risks those arrangements may pose, and banks' responsibility to...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

Spilman Thomas & Battle, PLLC

Promissory Notes - Banking & Finance Insights: V 4, Issue 1, January 2024

OCC Issues Guidance on ‘Buy Now, Pay Later’ Lending - “The guidance notes that banks should maintain underwriting, repayment terms, pricing, and safeguards that minimize adverse customer outcomes and should ensure that...more

Mayer Brown

Private Credit Reporting Requirements Proposed by US Banking Regulators

Mayer Brown on

On December 27, 2023, the US federal banking regulators proposed a new set of reporting requirements for bank loans and commitments to private credit lenders and intermediaries....more

Pillsbury Winthrop Shaw Pittman LLP

Federal Banking Regulators Issue Final Rule Overhauling Community Reinvestment Act Regulations

The expansive final rule overhauls how banks are evaluated for lending to low- and moderate-income customers. The federal banking regulators issued a joint final rule that will govern Community Reinvestment Act (CRA)...more

Venable LLP

Financial Regulatory Reform Tracker - Anti-Tailoring Efforts

Venable LLP on

Following the 2023 bank failures, the federal banking regulators (the Federal Reserve, the OCC, and the FDIC) have signaled that they are seeking to develop more stringent bank regulatory requirements for larger banking...more

Goodwin

Federal Banking Agencies Propose Basel III Endgame Capital Rules

Goodwin on

On July 27, 2023, the Federal Reserve, FDIC, and OCC issued a notice of proposed rulemaking and request for comment on a proposal (the Proposal) to implement the final components of the Basel III Capital Accords, often...more

Cadwalader, Wickersham & Taft LLP

Capital Idea? Risk-Based Capital, Capital Relief Trades and the Proposed Basel III Endgame Capital Rules

On July 27, 2023, the U.S. federal prudential bank regulators (the Federal Deposit Insurance Corporation, the Federal Reserve Board (“FRB”) and the Office of the Comptroller of the Currency) proposed new capital requirements...more

Hudson Cook, LLP

Federal Bank Regulatory Agencies Issue Final Joint Guidance for Managing Third-Party Relationship Risks

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On June 6, 2023, the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, and the Office of the Comptroller of the Currency issued final joint guidance addressing bank management of...more

Goodwin

Bank Regulators Issue Guidance for Third-Party Risk Management

Goodwin on

On June 6, 2023, the Board of Governors of the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, Agencies)...more

Nutter McClennen & Fish LLP

Nutter Bank Report: June 2023

The federal banking agencies have published new guidance to help banking organizations manage risks associated with third-party relationships, including relationships with financial technology (fintech) companies. The new...more

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