Becoming or owning an industrial loan company (or ILC)—the elusive "nonbank bank" option, as Congress coined the term in 1987— still has an allure for financial services providers that want to (1) lend on a national scale...more
It is no secret that the Federal Reserve, the FDIC, and the OCC have zeroed in on banks' use of third parties for products, services, and other operations, the risks those arrangements may pose, and banks' responsibility to...more
5/14/2024
/ Banking Regulators ,
Banking Sector ,
Banks ,
Community Banks ,
Enforcement ,
Enforcement Actions ,
FDIC ,
Federal Reserve ,
Final Guidance ,
Financial Institutions ,
Joint Policy Statements ,
New Guidance ,
Nonbank Firms ,
OCC ,
Regulatory Oversight ,
Risk Management ,
Third-Party ,
Third-Party Risk
A U.S. District Court recently rejected arguments that banks and institutions with novel charters have a statutory right to obtain a Federal Reserve master account. Master accounts let institutions access key parts of the...more
Since the 2023 spring bank failures, the federal banking agencies have tinkered with significant bank regulations and guidance—ranging from capital, bail-in measures, and resolution planning to climate-risk stress testing,...more
After more than five years—with competing developments at times—the federal banking agencies (Federal Reserve, OCC, and FDIC) have revamped the regulations that implement the Community Reinvestment Act (CRA).
The final...more
Besides being a shock to the market, the 2023 bank failures caused many to ask whether the federal banking agencies had done enough to prevent them. Precisely what the agencies should have done, or should do moving forward,...more
9/13/2023
/ Banking Sector ,
Banks ,
BSA/AML ,
Compliance ,
Enforcement Priorities ,
Federal Reserve ,
Financial Crisis ,
Financial Services Industry ,
Proposed Regulation ,
Silicon Valley ,
Supervision
Following the 2023 bank failures, the federal banking regulators (the Federal Reserve, the OCC, and the FDIC) have signaled that they are seeking to develop more stringent bank regulatory requirements for larger banking...more
8/29/2023
/ Banking Regulators ,
Banking Sector ,
Banks ,
Capital Requirements ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
Liquidity ,
OCC ,
Proposed Rules ,
Regulatory Agenda ,
Regulatory Requirements
On August 8, 2023, the Federal Reserve released new guidance for supervised banking organizations on how they can engage in certain crypto-asset-related activities. With the release of the guidance, the Federal Reserve...more