On June 24, the Office of the Comptroller of the Currency (OCC) announced it is requesting comments on proposed amendments to its recovery planning guidelines. A recovery plan’s purpose is to provide a covered bank with a...more
There has been a great deal of press about the Federal Trade Commission’s (FTC) vote to ban employee non-competition provisions and policies. While the FTC describes the rule as a comprehensive ban, it acknowledges that the...more
4/30/2024
/ Banks ,
Credit Unions ,
Employees ,
Employer Liability Issues ,
Employment Contract ,
Federal Trade Commission (FTC) ,
Final Rules ,
Financial Institutions ,
FTC Act ,
Non-Compete Agreements ,
Section 5 ,
Unfair or Deceptive Trade Practices
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
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 July 27, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (collectively, the agencies) issued a joint notice of proposed...more
On July 18, Office of the Comptroller of the Currency (OCC) Senior Deputy Comptroller for Large Bank Supervision Greg Coleman testified on OCC supervision of climate-related financial risks before the U.S. House of...more
On May 25, the Office of the Comptroller of the Currency (OCC) announced that it has revised its manual on bank enforcement actions to specifically address banks that exhibit or fail to correct persistent weaknesses. The...more
On May 23, Chairman Martin J. Gruenberg of the Federal Deposit Insurance Corporation (FDIC) delivered remarks at the Cities for Financial Empowerment Fund 2023 Bank On National Conference. One of the focuses of the Chairman’s...more
Today, the Federal Deposit Insurance Corporation (FDIC) published a notice of proposed rulemaking that would impose special assessments to recover losses to the Deposit Insurance Fund (DIF) arising from the FDIC’s protection...more
On May 1, the Federal Deposit Insurance Corporation (FDIC) released a report titled Options for Deposit Insurance Reforms, which outlines three options to reform the nation's deposit insurance system. The three options...more
On April 12, at a roundtable discussion hosted by the Bipartisan Policy Center Federal Deposit Insurance Corporation (FDIC) Vice Chair Travis Hill opined that the following potential regulatory responses to the failure of...more
On March 10, the California Department of Financial Protection and Innovation closed Silicon Valley Bank and appointed the Federal Deposit Insurance Corporation (FDIC) as its receiver. Silicon Valley Bank had 17 branches in...more
On April 11, Virginia enacted a new law (HB 263), which goes into effect on July 1, 2022, permitting “banks” to provide customers with “virtual currency custody services so long as the bank has adequate protocols in place to...more
In a CFPB blog post from December 9, the CFPB stated that the FDIC Board of Directors (FDIC Board) had promulgated a request for information (RFI) regarding a review of the Bank Merger Act criteria for approving bank mergers...more
On July 22, 2020, the Office of the Comptroller of the Currency (the OCC) confirmed in Interpretive Letter #1170 the authority of a national bank to provide cryptocurrency custody services. Since that time, the OCC has issued...more
On April 9, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies), in consultation with the Financial...more
Prior to the COVID-19 pandemic, many combined factors pushed the banking industry toward consolidation, greater efficiency, and in many instances, smaller branch footprints. When COVID-19 forced banks to close branch lobbies...more