On March 29, the Federal Crimes Enforcement Network (FinCEN), in collaboration with other federal agencies, issued a Notice and Request for Information and Comment (Notice and Request) seeking public comment on its proposal...more
Today, a divided Federal Deposit Insurance Corporation’s (FDIC) Board of Directors issued a proposed Statement of Policy (SOP) on bank merger transactions that would create a combined bank with more than $100 billion in...more
3/22/2024
/ Anti-Competitive ,
Bank Merger Act ,
Banks ,
Comment Period ,
Corporate Sales Transactions ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Merger Agreements ,
Money Laundering ,
OCC ,
Policy Statement
On March 12, at the Institute of International Bankers Annual Washington Conference, Acting Comptroller of the Currency Michael J. Hsu discussed the importance of operational resilience in the banking sector and hinted that...more
The Federal Deposit Insurance Corporation (FDIC) recently announced a consent order with Tennessee-based Lineage Bank containing orders relating to the bank’s third-party risk management program and its financial technology...more
As discussed here, on October 24, the Federal Reserve Board, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency finally issued their long-awaited final rule modernizing how they...more
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
2/1/2024
/ Bank Merger Act ,
Banks ,
BSA/AML ,
Comment Period ,
CRA ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Notice of Proposed Rulemaking (NOPR) ,
OCC ,
Policy Statement ,
Proposed Rules
On January 18, at an event hosted by Columbia University Law School, Acting Comptroller of the Currency Michael J. Hsu discussed liquidity risk at banks and described potential “targeted regulatory enhancements” that would...more
On January 12, Fiserv announced that it filed an application with the state of Georgia for a merchant acquirer limited purpose bank (MALPB) charter. This application is a seismic development and positive sign for those in the...more
On January 8, the Office of the Comptroller of the Currency (OCC) announced adjustments to the maximum amount of each civil money penalty (CMP) within its jurisdiction. The 2015 Adjustment Act requires federal agencies with...more
On January 2, New York Governor Kathy Hochul unveiled her 2024 consumer protection agenda, which includes plans to regulate the “buy now, pay later” (BNPL) industry. Specifically, Governor Hochul plans to propose legislation...more
On December 7, the Office of the Comptroller of the Currency (OCC) published the fall edition of its Semiannual Risk Perspective, which discusses key issues facing banks. From the OCC’s perspective, the overall strength of...more
12/11/2023
/ Artificial Intelligence ,
Banks ,
Beneficial Owner ,
BSA/AML ,
Customer Due Diligence (CDD) ,
Cyber Attacks ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
OCC ,
Risk Management ,
Suspicious Activity Reports (SARs)
This week, the Office of the Comptroller of the Currency (OCC) issued guidance to banks on managing the risks associated with “buy now, pay later” (BNPL) lending. Specifically, the bulletin addresses BNPL loans that are...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
11/8/2023
/ Banks ,
Dodd-Frank ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
FRB ,
FSOC ,
Nonbank Firms ,
Oral Hearings ,
Regulatory Agencies ,
Supervisory Guidance ,
U.S. Treasury
As discussed here, on August 1, the two major national credit union trade associations — the National Association of Federal Credit Unions (NAFCU) and the Credit Union National Association (CUNA) — announced plans to merge...more
On October 24, the Federal Reserve Board (Fed), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the agencies) finally issued their long-awaited final...more
10/26/2023
/ Community Reinvestment Act ,
CRA ,
Discriminatory Lending Practices ,
Equal Access to Credit ,
Fair Lending ,
FDIC ,
Federal Reserve ,
Final Rules ,
Financial Regulatory Reform ,
Financial Services Industry ,
FRB ,
Lenders ,
Notice of Proposed Rulemaking (NOPR) ,
OCC
On October 16, the Federal Reserve Board (Fed) published a notice of an Open Board Meeting to take place on October 25. The only matter under consideration at that meeting will be the Fed’s proposed revisions to the debit...more
10/20/2023
/ Administrative Procedure Act ,
Banks ,
Certiorari ,
Corner Post Inc v Board of Governors of the Federal Reserve System ,
Debit Cards ,
Dodd-Frank ,
Durbin Amendment Rules ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Interchange Fees ,
Public Comment ,
Statute of Limitations
On August 1, the two major national credit union trade associations — the National Association of Federal Credit Unions (NAFCU) and the Credit Union National Association (CUNA) — announced plans to merge and create a new...more
On August 29, the Board of Governors of the Federal Reserve System (Federal Reserve), Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller of the Currency (collectively, the agencies) issued a notice of...more
On August 8, the Federal Reserve Board (Fed) issued a press release providing additional information on its Novel Activities Supervision Program (Program) to monitor novel activities in the banks it oversees. Novel activities...more
8/17/2023
/ Application Programming Interface (APIs) ,
Banks ,
Blockchain ,
Cryptoassets ,
Cryptocurrency ,
Digital Assets ,
Distributed Ledger Technology (DLT) ,
Financial Institutions ,
Financial Services Industry ,
Securities and Exchange Commission (SEC) ,
Virtual Currency
In June, the Consumer Financial Protection Bureau’s (CFPB) Office of Competition and Innovation and Office of Markets issued an analysis of deposit insurance coverage on funds stored through popular payment companies, finding...more
On June 29, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, and the National Credit Union Administration (collectively, the agencies)...more
On June 21, the Consumer Financial Protection Bureau (CFPB) released two reports detailing access to banking and the financial experience of consumers living in the Southern states. Many areas of the South are considered...more
At a Peterson Institute for International Economics event on June 22, Federal Deposit Insurance Corporation (FDIC) Chairman Martin Gruenberg announced that the FDIC — along with the Board of Governors of the Federal Reserve...more
On June 16, The Board of Governors of the Federal Reserve System (Federal Reserve) launched its Master Account and Services Database, providing a searchable database on which financial institutions have access to the Federal...more
On June 22, the Office of the Comptroller of the Currency (OCC) released Version 1.0 of its Asset Management booklet, which provides an overview of sound risk management processes for bank asset management. The OCC will apply...more