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Office of the Comptroller of the Currency Internal Controls

The Volkov Law Group

TD Bank Eats $225 Million Termination Fee After AML Failures Doom Merger

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How much is an effective Anti-Money Laundering (“AML”) Compliance Program Worth? For Toronto-Dominion Bank (“TD”), the answer is at least $225 million––the amount that TD must now pay to First Horizon Bank, after backing...more

Latham & Watkins LLP

Acting Comptroller Confronts “Too Big to Manage” Issue

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The Acting Comptroller of the OCC discussed the limits of large bank manageability and the steps that regulators can take to address the risks posed by size and complexity. On January 17, 2023, Acting Comptroller of the...more

Holland & Knight LLP

The Impact of Cybersecurity Regulations on the Financial Services Industry in 2022

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Following the SolarWinds and the Colonial Pipeline cyberattacks, the Biden Administration emphasized a shift toward mandatory cybersecurity requirements. Throughout 2021, government agencies issued new cybersecurity guidance,...more

Eversheds Sutherland (US) LLP

Federal Banking Regulators Shine Light Again on Third-Party Risk Management

Federal banking regulators have again demonstrated their focus on bank oversight and management of risk from third party relationships through a series of guidance and proposed guidance published in the third quarter of 2021....more

Kaufman & Canoles

Credit Union Client Alert – Wells Fargo Must Pay $250 Million Fine

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The Office of the Comptroller of the Currency (OCC) issued a $250 million civil penalty against Wells Fargo Bank, NA for flaws in the bank’s home loan loss mitigation program. In addition, the OCC issued a cease-and-desist...more

Health Care Compliance Association (HCCA)

Citigroup pays $400 million and must overhaul internal controls

Compliance Today (January 2021) - Just a few months before Jane Fraser takes over as chief executive officer—the first woman to run a major Wall Street bank —Citigroup agreed to pay $400 million to settle an Office of the...more

The Volkov Law Group

OCC Fines JP Morgan Chase $250 Million for Deficient Internal Controls

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Banking regulators have been flexing their muscles.  With the coming Biden Administration, this may portend the beginning of a new, enforcement wave.  Some have suggested that banks are resolving these cases before a more...more

Robins Kaplan LLP

Financial Daily Dose 10.8.2020 | Top Story: Feds fine Citi $400M over “Longstanding” Governance Failures

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Federal regulators—including the Federal Reserve and the OCC—have fined Citigroup $400 million over “longstanding” failures in the areas of risk management, data governance, and internal controls. In addition to the fine, the...more

Manatt, Phelps & Phillips, LLP

Cryptocurrency Custody Activities Confirmed for National Banks—But With Caution

Following ongoing efforts to promote the expansiveness of the national bank charter, on July 22, 2020, the Office of the Comptroller of the Currency (OCC) issued an interpretive letter confirming the authority of a national...more

Moore & Van Allen PLLC

OCC Releases Bulletin on Fraud Risk Management Principles

In the aftermath of sales practices, the Office of the Comptroller of the Currency (OCC) recently published a bulletin on fraud risk management principles that are applicable to all federally chartered financial institutions....more

Troutman Pepper

Wells Fargo Consent Orders Highlight Importance of Acting on Information From Third-Party Vendors

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The OCC and CFPB consent orders issued against Wells Fargo on April 20 cited deficiencies in third-party oversight practices. The orders are the latest additions to an ever-expanding body of agency enforcement actions...more

Vedder Price

The OCC Speaks: How FinTech Applications Will Be Reviewed

Vedder Price on

On March 15, 2017, the Office of the Comptroller of the Currency (the “OCC”) published for comment a draft supplement to the OCC’s existing Comptroller’s Licensing Manual providing detail on how the OCC will evaluate national...more

WilmerHale

OCC Revises CMP Policy

WilmerHale on

For the first time in over twenty years, the Office of the Comptroller of the Currency (OCC) has formally changed its policy governing civil money penalties (CMP) against national banks, federal savings associations, federal...more

Troutman Pepper

Observation 3.0: Frequently Asked Questions and Answers on the Volcker Rule and the Implications for Foreign Banks Investing in...

Troutman Pepper on

1. Question: What is the Volcker Rule, and when does it take effect? Answer: The Volcker Rule was enacted into law as section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank...more

Morrison & Foerster LLP - Structured Products

Structured Thoughts: News for the financial services community, Volume 6, Issue 6

U.S. Structured Warrant Programs: Introduction - U.S. and non-U.S. banks have offered structured warrants in the U.S. to address the needs of both institutional and high-net worth investors. This article will...more

Goodwin

Financial Services Weekly News Roundup - October 2014

Goodwin on

Editor’s Note: Spotlight on the Federal Reserve and CSBS 2014 Community Banking Report. On September 24 the Federal Reserve and the Conference of State Bank Supervisors (CSBS) announced the release of their report,...more

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