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Office of the Comptroller of the Currency Commercial Loans

Latham & Watkins LLP

OCC Issues Policy Guidance on Venture Loans

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The OCC outlines safety and soundness principles and appropriate risk management processes for its regulated institutions that engage in venture lending. On November 1, 2023, the Office of the Comptroller of the Currency...more

Sheppard Mullin Richter & Hampton LLP

OCC Issues Bulletin on Risks Related to Venture Lending

On November 1, the OCC issued Bulletin 2023-34 addressing the topic of “venture lending,” referred to as “commercial loans to early-, expansion-, and late-stage companies.” According to the Bulletin, venture lending is often...more

Stinson LLP

New Interagency Policy Statement on CRE Loan Accommodations and Workouts

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On June 29, 2023, a new interagency Policy Statement (the Statement) was issued relating to commercial real estate (CRE) loan accommodations and workouts. The Statement is relevant to all financial institutions governed by...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

Goodwin

Federal Reserve and OCC Release 2023 Bank Stress Test Scenarios

Goodwin on

On February 9, the Federal Reserve released its hypothetical scenarios for its 2023 bank stress tests, and on February 10, the OCC also released hypothetical economic and financial market scenarios to be used by covered...more

Perkins Coie

Fintech Week in Review - January 2021

Perkins Coie on

FDIC Creates New Exceptions for Fintech Companies with Its Final Brokered Deposit Rule - On December 15, 2020, the Federal Deposit Insurance Corporation (FDIC) finalized its updated brokered deposit rule, providing...more

Butler Snow LLP

FFIEC Issues New Guidance on Loan Accommodations Related to COVID-19

Butler Snow LLP on

At the onset of the pandemic, many financial institutions offered credit accommodations, such as short-term deferrals and other loan modifications, to borrowers in response to the significant adverse impact caused by...more

Nutter McClennen & Fish LLP

Fintech in Brief: OCC Issues Final ‘Valid When Made’ Rule on Permissible Interest on Transferred Loan

On May 29, 2020, the Office of the Comptroller of the Currency (the “OCC”) issued a final rule (the “Rule”) confirming the validity of interest rates on bank loans transferred to third parties, including fintech affiliates....more

Nutter McClennen & Fish LLP

Nutter Bank Report: Special Edition: Working with Customers Affected by COVID-19

The FDIC, OCC, and Massachusetts Division of Banks (DOB) each have recently issued updated guidance on accommodations for customers that banks should consider to address the financial needs of borrowers and depositors who...more

Troutman Pepper

FDIC And OCC Issue Strong Rebuke To Madden In Joint Amicus Brief: 'madden Is Not Just Wrong; It Is Unfathomable'

Troutman Pepper on

On September 10, the FDIC and the OCC jointly submitted an amicus brief to the U.S. District Court for the District of Colorado in support of the appellee debt buyer in In re Rent-Rite Super Kegs West Ltd. ...more

Dechert LLP

Securitizing Marijuana Dispensary Properties in the Sessions Era

Dechert LLP on

In 2013, the Obama administration issued the Cole Memorandum, which called a truce between federal prosecutors and marijuana businesses operating legitimately under state law. After regime change in Washington, however, it...more

Stinson LLP

Emerging Trends Newsletter - Q4

Stinson LLP on

The Volcker Rule Under the Trump Administration - The so-called Volcker Rule—named after Paul Volcker, a former chairman of the Federal Reserve Board—was part of the Dodd-Frank Wall Street Reform and Consumer Protection...more

Polsinelli

2017 OCC Bank Supervision Plan, House Committee Passes Dodd-Frank Reform

Polsinelli on

OCC Releases 2017 Bank Supervision Plan - The OCC’s Committee on Bank Supervision (CBS) yesterday published its Fiscal Year 2017 Bank Supervision Operating Plan and announced the following five oversight objectives...more

Goodwin

Agencies Re-Propose Rule Implementing Risk Retention Requirements of Dodd-Frank Act

Goodwin on

On August 28, 2013, the FDIC, OCC, FRB, SEC, Federal Housing Finance Agency, and Department of Housing and Urban Development (collectively, the “Agencies”) issued a second Notice of Proposed Rulemaking (the “revised...more

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