Alex Barrage, a partner in Troutman Pepper Locke’s Financial Services Industry Group, was quoted in the February 6, 2025 Banking Dive article, “Concerns Mount Over FDIC Staffing Challenges.”...more
Supervision is a daily fact of life for bank boards and management. Below, we offer strategies for how both board members and members of management can ensure that the supervisory process goes as smoothly as possible....more
I’ve written at least a dozen articles about the dramatic impact the new CRA is going to have on banks. Until now, only about 1.2% of bank CRA examinations end with a failing grade. But, by the estimates of the regulators, if...more
In my previous email I explained the devastating impact of the new CRA Rule on the percentage of banks receiving a less than satisfactory CRA Performance Rating. The data in Table 32 within the new Rule demonstrate that if...more
With all the news stories circulating about the new CRA Rule, it's surprising that not one article has addressed the topic that should be the biggest story of all - the catastrophic implications for banks!...more
The Federal Deposit Insurance Corporation has announced that it is launching a new Banker Engagement Site (BES) this month through FDICconnect to serve as the primary tool for exchanging examination planning and other...more
Federal Reserve Considers Merits of Creating a U.S. Dollar Digital Currency The Federal Reserve has published a discussion paper that examines the pros and cons associated with the creation of a U.S. central bank digital...more
Why communication and documentation are key for banks. It goes without saying that a regulatory exam can be stressful for financial institutions even under otherwise “normal” operating conditions. However, add in the...more
A January proposal to give banks compliance slack floated by a high-ranking Federal Reserve Board (“FRB”) official has not yet gained the traction its supporters had hoped for. In remarks before the American Bar Association...more
Bank examinations, holding company inspections and other “supervisory events” can be a source of anxiety and dread for those who work in the banking industry. Originally published in ABA Bank Compliance - March/April 2020....more
The Financial Crimes Enforcement Network (FinCEN) has proposed long-expected regulations that would extend anti-money laundering (AML) requirements to federally registered investment advisers (RIA). The August 25, 2015...more
The Federal Financial Institutions Examination Council (FFIEC) has released its revised Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual. The revisions clarify supervisory expectations and incorporate...more