News & Analysis as of

Administrative Proceedings Office of the Comptroller of the Currency Constitutional Challenges

Orrick, Herrington & Sutcliffe LLP

Fifth Circuit upholds OCC enforcement action, finding Jarkesy ruling does not bar in-house proceedings

On September 8, the U.S. Court of Appeals for the Fifth Circuit denied a petition for review brought by two former executives of a failed Texas bank, upholding industry bans and $250,000 in civil penalties imposed by the OCC....more

Ballard Spahr LLP

SCOTUS decision in Seila Law holding CFPB structure unconstitutional would not impact OCC or HUD

Ballard Spahr LLP on

The constitutional question that the U.S. Supreme Court has agreed to decide in Seila Law is whether the CFPB’s single-director-removable-only-for-cause structure violates separation of powers.  A ruling by the Supreme Court...more

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