The CFPB has revised its internal supervisory appeals process for institutions seeking to appeal a compliance rating or an adverse material finding. The revisions became effective immediately upon publication in the Federal...more
On February 16, 2024, the Consumer Financial Protection Bureau (CFPB) issued a procedural rule revising its supervisory appeals process for the first time since 2015. This Rule makes several important changes...more
On February 6, 2024, National Credit Union Administration (NCUA) Chairman Todd M. Harper spoke at a Brookings Institution event to outline his regulatory agenda and supervisory priorities for 2024. His prepared remarks...more
On January 23, the Chairman of the National Credit Union Administration (NCUA) released a letter outlining its supervisory priorities for the new year. While the organization acknowledged that the credit union system had...more
Rebecca Jackson, Executive Director, Authorisations, Regulatory Technology, and International Supervision at the Prudential Regulation Authority ("PRA") has written to international banks on the PRA’s thematic supervision...more
The Situation: In October 2023, the Office of the Comptroller of the Currency ("OCC"), Federal Reserve System, and Federal Deposit Insurance Corporation ("FDIC," and the three agencies collectively, "Agencies") finalized...more
On November 3, the Financial Stability Oversight Council (FSOC) voted unanimously to finalize the procedures for designating a nonbank financial company for Federal Reserve supervision. FSOC’s Interpretive Guidance aims to...more
On October 4, 2023, the Office of the Superintendent of Financial Institutions (“OSFI”) released details of a new supervisory framework (“New Framework”) that will apply as of April 1, 2024 to federally-regulated financial...more
The Office of the Comptroller of the Currency’s (OCC) Committee on Bank Supervision (CBS) recently issued its annual Bank Supervision Operating Plan for FY 2024, which sets forth the OCC’s supervision priorities and...more
The FDIC has filed motion to dismiss the lawsuit filed in July 2023 in a Minnesota federal district against the FDIC and its Chairman seeking to invalidate the FDIC’s supervisory guidance on charging multiple non-sufficient...more
Earlier this month, the Federal Reserve Board (FRB) released two supervision and regulation letters regarding the agency’s program to supervise “novel” banking activities....more
On Monday, Federal Deposit Insurance Corporation (“FDIC”) Chair Martin Gruenberg gave remarks to the Brookings Institution on “The Resolution of Large Regional Banks.” Chair Gruenberg did not say “I told you so” in his...more
In April 2022, the Basel Committee on Banking Supervision (the Basel Committee) began a review of “the core principles for effective banking supervision” (Core Principles or CP). Last month, the Basel Committee published...more
The Federal Reserve issued a Supervision and Regulation letter earlier this week to all state member banks (“SMBs”) regarding their involvement in activities involving stablecoins, taking an even more reticent position than...more
Earlier this week, the Federal Reserve issued a Supervision and Regulation Letter regarding the “Creation of Novel Activities Supervision Program” (SR 23-7). The letter informs all banking organizations subject to supervision...more
In April 2022, the Basel Committee on Banking Supervision (the Basel Committee) began a review of “the core principles for effective banking supervision” (Core Principles or CP). Last month, the Basel Committee published a...more
A complaint filed on July 20, 2023 in Minnesota federal court seeks declaratory and injunctive relief under the Administrative Procedures Act (APA) against defendants Federal Deposit Insurance Corporation (FDIC) and Chairman...more
On July 18, Office of the Comptroller of the Currency (OCC) Senior Deputy Comptroller for Large Bank Supervision Greg Coleman testified on OCC supervision of climate-related financial risks before the U.S. House of...more
On July 6, 2023, the Basel Committee on Banking Supervision (“Basel Committee”) released proposed revisions to its core principles for effective banking supervision (the “Revised Principles”). The Revised Principles are...more
On January 27, the Federal Reserve Board issued a policy statement providing guidelines on how the agency evaluates requests from supervised uninsured and insured banks seeking to engage in novel activities, such as those...more
On May 17, the Federal Deposit Insurance Corporation (“FDIC”) issued Financial Institutions Letter 22-2022 updating the FDIC’s Guidelines for Appeals of Material Supervisory Determinations. The revised Guidelines restore the...more
On November 3, 2021, the New York Department of Financial Services (DFS) announced the creation of a new Climate Risk Division (the Division) that is tasked with integrating climate risks into DFS’s supervision of regulated...more
On February 26, 2021, the Federal Reserve issued Supervisory Guidance (SG) for the Board of Directors (BOD) of Domestic Bank and Savings and Loan Holding Companies requiring effective BOD oversight. ...more
In This Issue. President Biden signed a bill extending the Small Business Administration’s (SBA) Paycheck Protection Program (PPP) through May 31, 2021; the Consumer Financial Protection Bureau (CFPB) announced the rescission...more
On October 20, 2020, a consortium of U.S. federal financial regulators (Regulators), issued a proposed rule (Proposed Rule) that, if enacted, would codify that mere supervisory guidance that is not the product of notice and...more