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Acting Comptroller Confronts “Too Big to Manage” Issue

The Acting Comptroller of the OCC discussed the limits of large bank manageability and the steps that regulators can take to address the risks posed by size and complexity. On January 17, 2023, Acting Comptroller of the...more

Banking Regulators Issue Joint Statement on Crypto Risks

Banking organizations should ensure appropriate risk management, but regulators are skeptical of certain crypto activities as principal. On January 3, 2023, the Board of Governors of the Federal Reserve System (Federal...more

NYDFS Proposes Guidance on Climate Change Risk Management

The Guidance would increase expectations for regulated financial institutions to identify, measure, monitor, and control climate-related financial risks. For the past few years, the New York State Department of Financial...more

Federal Reserve Proposes Climate Risk Guidance for Large Financial Institutions

The guiding principles are similar to related proposals from other banking regulators, but will require further clarification through the comment process. On December 2, 2022, the Board of Governors of the Federal...more

Federal Reserve Issues Cryptoasset Engagement “Rules of the Road” for Its Supervised Banking Organizations

The Federal Reserve is taking measured steps to better understand the types of cryptoasset-related activities contemplated by its supervised banking organizations. On August 16, 2022, the Board of Governors of the...more

US Federal Banking Agencies Introduce Further Measures to Address Continuing COVID-19-Related Risks

The three US federal banking agencies continue to take additional steps to promote the functioning of the financial system in the face of the pandemic. The three US federal banking agencies - the Board of Governors of the...more

US Federal Banking Agencies Introduce Additional Measures to Address COVID-19-Related Risks

The three US federal banking agencies have taken additional steps to enable the financial system to continue functioning during the pandemic. The three US federal banking agencies — the Board of Governors of the Federal...more

The Systemic Importance of Cloud-Based Service Providers to Banks

US lawmakers urge FSOC to designate cloud-based storage systems used by major banks as systemically important financial market utilities. In an August 22, 2019, letter addressed to Treasury Secretary Steven Mnuchin, in his...more

Financial Institutions Await Response to Concerns Over NYSDFS’ Proposed Cybersecurity Rules

Comments submitted on the proposed regulations criticize the lack of a risk-based approach, overbroad definitions, potential extraterritorial implications, an excessive breach notification threshold and a daunting annual...more

New York State Department of Financial Services Releases Final Regulations to Enhance Anti-Money Laundering and Sanctions...

Final regulations impose certification requirements on a financial institution’s Board of Directors or Senior Officer(s) relating to BSA/AML and OFAC compliance. The New York State Register today published the final...more

Revised Rules on Dodd-Frank Incentive Compensation Requirements for Financial Institutions Proposed

If adopted, the Proposed Rule would have a significant impact on compensation practices at covered institutions. On April 21, 2016, the National Credit Union Administration (the NCUA) issued a proposed rule regarding...more

New York State Department of Financial Services Proposes Regulations to Enhance Anti-Money Laundering and Sanctions Compliance for...

Proposed regulations impose new certification requirements that could result in personal liability for compliance officers of financial institutions. On December 1, 2015, the New York State Department of Financial...more

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