Climate Risk, the emerging risk
Consumer Finance Monitor Podcast Episode: Community Reinvestment Act Reform: A Close Look at the Final Rule
Consumer Finance Monitor Podcast Episode: What the Recent Developments in Federal Preemption for National and State Banks Mean for Bank and Nonbank Consumer Financial Services Providers
Federal Banking Interagency Final Guidance on Third-Party Relationships - The Consumer Finance Podcast
Corruption, Crime and Compliance : CFPB and OCC Hit Bank of America with $250 Million Penalty for Consumer Abuse Practices
CFPB's Section 1071 Final Rule (Part 3): Potential Problem Areas – The Consumer Finance Podcast
Crypto Year in Review 2022: Federal Reserve and Central Bank Digital Currencies and FDIC/OCC Regulatory Developments - The Crypto Exchange Podcast
Crypto Enforcement Is Here, and Always Has Been
Congressional and Federal Agency Action Following Executive Order on Digital Assets Policy
Guidepost in Motion: Banking on Crypto
Compliance into the Weeds: Episode 161-OCC Guidance on 3rd Party Risk Management
Episode 127 -- Deep Dive into the OCC Enforcement Action Against Wells Fargo CEO and Senior Executives
Dealing with an Unsolicited Offer - The Bank Account
The Community Reinvestment Act (CRA): Recap and What to Expect in 2014
The New Normal: Taking Responsibility for Your Vendors
The Cozen Lens- •With Super Tuesday, the State of the Union, and the release of President Biden’s FY25 budget, this past week has been a politically consequential one. This series of events mark the pivot to the general...more
On June 29, 2023, the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, and National Credit Union Administration (the agencies) jointly issued...more
On June 14, 2023, the Office of the Comptroller of the Currency (OCC) published its Semiannual Risk Perspective which identifies key issues facing the federal banking system. This highly anticipated report comes in the wake...more
The Board of Governors of the Federal Reserve System, Office of the Comptroller of the Currency, National Credit Union Administration, and Federal Deposit Insurance Corporation (collectively, the “Agencies”) issued a joint...more
On June 30, the Federal Reserve Board (“FRB”), Federal Deposit Insurance Corporation (“FDIC”), Office of the Comptroller of the Currency (“OCC”) and the National Credit Union Administration (“NCUA”) finalized their Policy...more
The OCC, FDIC, NCUA and Fed have adopted a new Policy Statement on Prudent Commercial Real Estate Loan Accommodations and Workouts. The new policy statement updates, expands on and supersedes existing guidance from 2009,...more
The Federal Reserve, OCC and FDIC have (finally) issued the Final HVCRE Rule (for background, our analysis of the 2018 Notice of Proposed Rulemaking and 2019 Notice of Proposed Rulemaking are here and here), regarding High...more
On April 2, 2018, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency issued a final rule that increases the threshold for...more
Editor's Note - Treasury Issues Recommendations to Modernize the Community Reinvestment Act. On April 3, the U.S. Department of the Treasury released a report containing its recommendations for modernizing the Community...more
On September 27, 2017, the principal federal banking agencies, the Board of Governors of the Federal Reserve, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency, released a Notice of...more
California Appellate Court Overturns “Sham Guaranty” Defense - The single-purpose entity (SPE) has become a ubiquitous tool in commercial real estate acquisitions and financing in California. Lenders increasingly require...more
House Financial Services Committee Votes To Repeal And Replace Dodd-Frank - On September 13th, the House Financial Services Committee approved the Financial CHOICE Act of 2016 to repeal and replace key parts of the 2010...more
According to its Semiannual Risk Perspective for Spring 2016 (the “Semiannual Risk Report”), the National Risk Committee of the Office of the Comptroller of the Currency (the “OCC”) has escalated its oversight of commercial...more
On October 22, 2014, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Securities and Exchange Commission, the Federal Housing...more
In the ancient world kings and emperors regularly sought advice from the Oracle at Delphi when making important decisions. The Oracle would respond to questions, sometimes in poetry, other times in prose, in a manner that...more
Why it matters - In a statement expressing concern about the growth of commercial real estate (CRE) lending, the federal banking agencies stressed the need to utilize "prudent risk-management practices." The Board of the...more
Well, Halloween has come and gone and with the annual bacchanal of faux frisson over zombies, vampires and the like behind us, can we also put away risk retention anxieties like one of those annoying and morally disturbing...more
Over the last few weeks, I’ve commented on the new version of the OCC’s Commercial Real Estate Lending Handbook (I give it a gentlemen’s C); and I listed a few legal topics that deserve some guidance from the OCC. ...more
Last month, the Office of the Comptroller of the Currency published the Commercial Real Estate Lending handbook (August 2013). The 128 page handbook gives guidance to bank examiners and bankers on risks inherent in...more
On August 20, the Office of the Comptroller of the Currency (OCC) issued the “Commercial Real Estate Lending“ booklet of the Comptroller’s Handbook to replace the OCC’s “Commercial Real Estate and Construction Lending”...more
In this issue: - SEC, CFTC and FINRA Issue Joint Advisory on Business Continuity and Disaster Recovery Planning - FINRA Updates Private Placement Form and Issues FAQ - SEC Approves Amendments to FINRA...more