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New OCC Guidance on Community Reinvestment Act (CRA) Ratings

On October 12, 2017, the OCC issued OCC Bulletin 2017-40 announcing the release of its Policies and Procedures Manual 5000-43 (PPM 5000-43), which outlines the OCC’s policy and framework for how the agency determines...more

2018 OCC Bank Supervision Operating Plan Observations

Here are our observations on the 2018 OCC Bank Supervision Operating Plan: – Cybersecurity is a top priority. – Credit underwriting, as always. – BSA is frequently mentioned...more

The OCC Speaks: How FinTech Applications Will Be Reviewed

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

It’s Not Much, but It’s a Start: The Regulators Freeze Certain Capital Requirements

On August 22, 2017, the Office of the Comptroller of the Currency (the “OCC”), the Federal Deposit Insurance Corporation (the “FDIC”) and the Board of Governors of the Federal Reserve System (the “FRB”) (the OCC, FDIC and FRB...more

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