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Proposed Rules Office of the Comptroller of the Currency Banks

Davis Wright Tremaine LLP

New Administration Outlook: FDIC Moves To Rescind Key, Controversial Proposals

The FDIC has signaled the reversal of key, controversial proposals from 2024. In doing so, it has provided welcome clarity on important areas that implicate banks of various sizes and charter types, allowing banks to focus on...more

Davis Wright Tremaine LLP

Bank Regulatory Considerations in a Second Trump Administration – What Could Change, What Could Stay the Same

While the coming weeks and months will provide more clarity, we already can anticipate some indications of what is in store for bank regulation, supervision, and enforcement in a second Trump Administration. To help navigate...more

DLA Piper

Bank Regulatory News and Trends

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This regular publication from DLA Piper focuses on helping banking and financial services clients navigate the ever-changing regulatory landscape. In this edition: CFPB issues final rule on personal financial data rights...more

Nutter McClennen & Fish LLP

Nutter Bank Report: September 2024

The FDIC, OCC, and U.S. Department of Justice (DOJ) have coordinated the release of new policies that will govern each agency’s consideration of bank merger transactions. The FDIC and OCC each published final statements of...more

Venable LLP

FDIC Finalizes Large Bank Resolution Plan Rule and OCC Proposes Changes to Recovery Plans

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The FDIC recently finalized its resolution planning rule for large banks, which becomes effective October 1, 2024. Resolution plans, or "living wills," are plans to wind down operations in the event of bank failures. The...more

Kilpatrick

Bank Regulators Revive Proposed Rules on Incentive Pay

Kilpatrick on

Three federal regulators have reproposed rules that implement the requirements for bank incentive compensation programs that were included in the Dodd-Frank legislation 14 years ago. Section 956 of Dodd-Frank required the...more

WilmerHale

The Drawbacks Of Banking Regulators' Merger Review Plans

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The Federal Deposit Insurance Corp. and the Office of the Comptroller of the Currency recently announced proposals to update their approaches to evaluating bank mergers and other business combinations under the Bank Merger...more

Orrick, Herrington & Sutcliffe LLP

OCC extends comment period on proposed rules for the Bank Merger Act

On April 10, the OCC announced a notice published in the Federal Register extending the comment period for the OCC’s proposed rule on bank mergers. The NPRM titled, “Business Combinations under the Bank Merger Act,” was...more

Proskauer - Regulatory & Compliance

Notice of Proposed Rulemaking under the Bank Merger Act to Increase Transparency

The U.S. Office of the Comptroller of Currency (OCC) released a notice of proposed rulemaking (NPR) seeking to “increase the transparency of the standards that apply to the agency’s review of business combinations involving...more

Jones Day

OCC Proposal and Policy Statement on Bank Mergers Could Freeze the Banking Industry in Place

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The Situation: On January 29, 2024, the Office of the Comptroller of the Currency ("OCC") requested comment on a proposed rule updating its bank merger rules and incorporating a policy statement (the "Proposal") on agency...more

Orrick, Herrington & Sutcliffe LLP

OCC issues proposed rule for bank merger approvals

On January 29, the OCC announced a proposed rule for bank merger approvals under the Bank Merger Act (BMA). The OCC proposed changes to 12 CFR 5.33 to reflect its view that a business combination is a significant corporate...more

Troutman Pepper Locke

OCC Proposes Rulemaking Amending Bank Merger Act Procedures to Eliminate Expedited and Streamlined Review and Add Policy Statement...

Troutman Pepper Locke on

On January 29, the Office of the Comptroller of the Currency (OCC) issued a notice of proposed rulemaking regarding its review of business combinations under the Bank Merger Act (BMA). Specifically, the OCC proposed: (i)...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

Nutter McClennen & Fish LLP

Nutter Bank Report: December 2023

A recent OCC report identified key issues facing the federal banking system, including increasing credit risk due to higher interest rates, increasing risk in commercial real estate lending, prolonged inflation, declining...more

Jones Day

Federal Banking Agencies Propose Long-Term Debt Requirements for Large Banks

Jones Day on

In Short: The Situation: The Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, and Federal Deposit Insurance Corporation (collectively, the "Agencies") have proposed rules...more

Cadwalader, Wickersham & Taft LLP

The Three Federal Banking Agencies Propose Long-Term Debt Requirement for All Large Banking Organizations

The Federal Deposit Insurance Corporation (“FDIC”), Federal Reserve Board (“FRB”) and Office of the Comptroller of the Currency (“OCC”) (together, the “Agencies”) issued a proposed rule (the “LTD NPR”) to require large banks...more

Venable LLP

Financial Regulatory Reform Tracker - Anti-Tailoring Efforts

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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

OCC Seeks Feedback on Principles for Climate-Related Financial Risk Management

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In this Issue. The Office of the Comptroller of the Currency (OCC) is seeking feedback on principles for climate-related financial risk management for large banks; the Department of Justice’s Antitrust Division is seeking...more

Perkins Coie

Fintech Legal Report - September 2021

Perkins Coie on

Federal Banking Agencies Issue Guide for Community Banks on Conducting Due Diligence on Fintech Companies - On August 27, 2021, the federal banking agencies (Federal Reserve, FDIC, and OCC) published “Conducting Due...more

Goodwin

CFPB Withdraws Proposal to Delay Debt Collection Final Rules

Goodwin on

In This Issue. The Consumer Financial Protection Bureau (CFPB) withdrew its proposal to delay the Debt Collection Final Rules; the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance...more

Goodwin

OCC Delays Publication Of Trump Administration “Fair Access” Rule

Goodwin on

In this Issue. The Office of the Comptroller of the Currency (OCC) delayed publication of the “fair access” rule finalized late in the Trump Administration; the OCC also announced the availability of the 2021 list of bank...more

Ballard Spahr LLP

OCC issues proposed rule on fair access to financial services

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The OCC has issued a proposed rule that would establish standards that a bank must follow in fulfilling its obligation to provide fair access to financial services.  Comments on the proposal are due by January 4, 2021....more

Bradley Arant Boult Cummings LLP

OCC Proposes Clarification to True Lender Doctrine

Earlier this week, the OCC released a proposed rule designed to address the “true lender” doctrine, a legal test utilized by courts and regulators to determine whether a bank or its non-bank partner is the actual lender in a...more

Goodwin

Financial Services Weekly News: Financial Regulators Respond To Coronavirus Outbreak

Goodwin on

In This Issue. The ongoing global outbreak of the coronavirus (COVID-19) continues to grow in scale and scope, creating public health and humanitarian challenges worldwide. Global economies are also being impacted. Federal...more

Orrick - Finance 20/20

Capital: Notice of Proposed Rulemaking

Orrick - Finance 20/20 on

On December 17, three entities – the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency – “published a notice of proposed rulemaking...more

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