News & Analysis as of

Office of the Comptroller of the Currency Banking Regulators

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

Ballard Spahr LLP on

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

Hudson Cook, LLP on

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

Pillsbury Winthrop Shaw Pittman LLP

Bank-Fintech Partnerships and Fair Lending: Top Areas at Risk for Government Scrutiny

The Federal Deposit Insurance Corporation (FDIC) recently published a consent order issued against Cross River Bank that alleged the bank’s fair lending program’s noncompliance and weaknesses in its oversight of fintech...more

Skadden, Arps, Slate, Meagher & Flom LLP

Recent Actions by the Fed Show Its Continued Cautious Approach to Cryptoasset Activities by Supervised Institutions

In the past year, the Board of Governors of the Federal Reserve System (the Board) Biden administration officials, and other U.S. banking regulators have repeatedly voiced growing concerns about certain cryptoasset...more

Latham & Watkins LLP

Banking Regulators Issue Joint Statement on Crypto Risks

Latham & Watkins LLP on

Banking organizations should ensure appropriate risk management, but regulators are skeptical of certain crypto activities as principal. On January 3, 2023, the Board of Governors of the Federal Reserve System (Federal...more

BakerHostetler

NFT Initiatives Launch Across Markets; US Banking Regulators Address Crypto; DOJ and Congress Target Crypto Fraud; FBI Cites Risks...

BakerHostetler on

NFT Initiatives Launch in Ticket Sales, Social Media and College Football - According to a recent press release, a major ticket sales and distribution company announced that event organizers who sell tickets on its platform...more

Moore & Van Allen PLLC

Risks Associated with Cryptocurrency Activities Continue to be Top-of-Mind for Federal Banking Regulators

Moore & Van Allen PLLC on

For those tracking developments impacting the crypto-asset space, the summer has been far from slow and leisurely. Multiple industry alerts flow daily with news of new legislative proposals, enforcement actions, and other...more

Buchalter

OCC Highlights Banks’ Compliance Staffing Issues, Even as Regulators Place More Compliance Demands on Banks and Place Executives...

Buchalter on

In its recent Semiannual Risk Perspective, the Office of the Comptroller of the Currency (OCC) has highlighted the difficulties banks face finding adequate numbers and quality of hires for compliance oversight. While there...more

Cadwalader, Wickersham & Taft LLP

In Depth: A Look at Federal Banking Agencies’ Proposal to Update Community Reinvestment Act Rules

As we mentioned briefly in our newsletter last week, the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board (“FRB”)  and the Office of the Comptroller of the Currency (“OCC”) (together, “The Agencies”)...more

Pillsbury Winthrop Shaw Pittman LLP

Federal Banking Regulators Propose Overhaul of Community Reinvestment Act

Regulators took a first step toward modernizing CRA regulations with a joint Notice of Proposed Rulemaking. The proposed rule would add more standardized metrics for regulators’ CRA examinations and more clearly delineate...more

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