In July, we discussed the federal banking agencies' proposal to harmonize their respective risk management guidance. At the time, we highlighted three passages from the proposal that relate to the due diligence banking...more
Last week, the federal banking agencies—Federal Reserve Board (Board), Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC)—issued proposed interagency guidance ("Proposal") on...more
Less than one month ago, Brian Brooks assumed the position of Acting Comptroller of the Office of the Comptroller of the Currency (OCC). Upon taking the position, Acting Comptroller Brooks released a statement outlining goals...more
On October 21, 2019, the District Court for the Southern District of New York entered a final judgment in favor of the New York State Department of Financial Services (NYDFS), blocking the Office of the Comptroller of the...more
There has been an unprecedented wave of consolidation in the U.S. payment processing industry this year, with two major core processors acquiring the two largest merchant acquirers, and two of the largest remaining payment...more