Understanding Scope of Practice
Evolving State Supervision: Issues Arising from State Qualification Standards and 'SAFE' Act Licensing, and Coordination with the CFPB
The Federal Financial Institutions Examination Council (“FFIEC”) published a statement on February 12, 2024 regarding “principles for the examination of supervised [institutions’] residential property appraisal and...more
On September 27, 2023, the Office of the Comptroller of the Currency (OCC) issued Version 2.0 of the Lease Financing booklet of the OCC’s Comptroller Handbook, which replaced Version 1.0 published in August 2014 and updated...more
A federal court has issued an order granting an injunction that delays the compliance dates for the CFPB’s final rule governing the collection of small business lending data required by Section 1071 of the Dodd-Frank Wall...more
On January 17, acting Comptroller of the Currency Michael J. Hsu delivered remarks at the Brookings Institute regarding large bank manageability. Hsu started by expressing his belief that developing a robust approach to...more
The Federal Reserve is taking measured steps to better understand the types of cryptoasset-related activities contemplated by its supervised banking organizations. On August 16, 2022, the Board of Governors of the...more
LPL may be the biggest BD in the country, with 21,500 reps operating out of almost 13,000 branch offices. Heaven knows how much money it brings in every year, but, goodness, it must be a lot. And good thing, too, given how...more
Federal Banking Agencies Issue New Guidance on Managing the LIBOR Transition - The member agencies of the Federal Financial Institutions Examination Council (“FFIEC”) have issued joint guidance for banking organizations...more
SEC Charges Trust Company with Operating Unregistered Investment Companies and Failing to Register Securities Offerings. On September 30, the Securities and Exchange Commission (SEC) announced it had settled charges with...more
On October 1st, the Office of the Comptroller of the Currency (OCC) published the Fiscal Year 2020 Bank Supervision Operating Plan (“FY 2020 Plan”). ...more
“Supervisory guidance does not have the force and effect of law, and the agencies do not take enforcement actions based on supervisory guidance.” On September 11, 2018, the Bureau of the Consumer Financial Protection,...more
The U.S. Office of the Comptroller of the Currency has announced updates to a number of supervision booklets, including the "Bank Supervision Process," "Community Bank Supervision," "Compliance Management Systems" and "Large...more
Notwithstanding the venerable status of the attorney client privilege and the important purposes it serves, the federal banking regulators and the Consumer Financial Protection Bureau have taken the position that they have...more
The US Office of the Comptroller of the Currency released its bank supervision operating plan for fiscal year (FY) 2017. The plan sets forth the foundation for policy initiatives and for supervisory strategies applicable to...more
The US Office of the Comptroller of the Currency released a mid-cycle status report on key actions that it has taken to date pursuant to its Committee on Bank Supervision’s annual operating plan for the fiscal year that...more
On December 3, 2015, the Office of the Comptroller of the Currency (“OCC”) provided updated guidance for its risk assessment system (“RAS”). The guidance (i) clarifies the relationship between RAS and the Uniform Financial...more
The Office of the Comptroller of the Currency (OCC) released its bank supervision operating plan for fiscal year 2016 on September 25th. The operating plan sets forth the agency’s supervision priorities and objectives as...more
A new report issued by the federal Office of the Comptroller of the Currency (OCC) identifies top safety and soundness risks to national banks and federal savings associations, as well as OCC supervisory priorities for the...more
In updated examiner guidance and examination procedures issued last week, the Office of the Comptroller of the Currency (OCC) directs its examiners to assess whether the overdraft protection and other deposit-related consumer...more
Editor’s Note - Spotlight on FINRA Retrospective Rule Review: On December 9, FINRA announced it had issued reports on its retrospective review of two groups of rules – a report on the rules on communications with the...more
The Office of the Comptroller of the Currency (OCC) on October 30 published revised policy and procedures for how it manages Matters Requiring Attention (MRAs) resulting from its examination of supervised institutions. MRAs...more