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On April 14, the OCC released a letter providing more details on the recent security breach involving its email systems. The breach — identified as a major incident under the Federal Information Security Modernization Act...more
On April 8, the OCC announced it had notified Congress of a major information security incident, as required by the Federal Information Security Modernization Act. The incident involved unauthorized access to emails and their...more
The National Credit Union Administration (NCUA) has approved a final rule requiring federally chartered and federally insured credit unions to notify NCUA of a "reportable cyber incident" "as soon as possible and no later...more
In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed rules to include certain significant market participants as “dealers” or “government securities dealers” to essentially eliminate the trader exclusion...more
In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed a new rule to increase market transparency regarding short selling and extended the comment period for its proposed rule requiring reporting on...more
In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed changes to private fund regulation; the Office of the Comptroller of the Currency (OCC) succeeded in validating its “valid-when-made” rulemaking; the...more
Following the SolarWinds and the Colonial Pipeline cyberattacks, the Biden Administration emphasized a shift toward mandatory cybersecurity requirements. Throughout 2021, government agencies issued new cybersecurity guidance,...more
On November 18, 2021, the Office of the Comptroller of the Currency (“OCC”), the Board of Governors of the Federal Reserve System (“Board”), and the Federal Deposit Insurance Corporation (“FDIC”) (collectively, the...more
Banking organizations must notify the appropriate agency within 36 hours of certain computer-security incidents; and banking service providers must notify affected banking organizations as soon as possible in the event of an...more
On November 18, 2021, three US agencies – the Office of the Comptroller of the Currency (OCC), the Federal Reserve Board (FRB) and the Federal Deposit Insurance Corporation (FDIC) – issued a joint rule concerning...more
On November 18, 2021, the Federal Deposit Insurance Corporation (FDIC), the Board of Governors of the Federal Reserve System (FRB), and the Office of the Comptroller of the Currency (OCC) issued a joint final rule (the...more
On November 18, 2021, the Federal Reserve, Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) approved a new final rule regarding reporting of cyber incidents for U.S. banks...more
In This Issue. Federal agencies issued a joint statement regarding an orderly transition away from the London Interbank Offered Rate (LIBOR); the Office of the Comptroller of the Currency (OCC) issued an updated...more
In This Issue. The Federal Deposit Insurance Corporation (FDIC) is seeking information and comment regarding the FDIC’s supervisory approach to examinations during the pandemic; the FDIC’s tech lab, FIDTECH, announced a “tech...more
The Office of the Comptroller of the Currency (OCC), the Federal Reserve Board (FRB), and the Federal Deposit Insurance Company (FDIC), have issued a notice of proposed rulemaking (Proposed Rule) that would require a banking...more
In the News. The Board of Governors of the Federal Reserve System (Federal Reserve) proposed rules to modernize the regulations that implement the Community Reinvestment Act (CRA); the Conference of State Bank Supervisors...more
In This Issue. The Securities and Exchange Commission (SEC) adopted amendments to its exemptive applications procedures under the Investment Company Act of 1940, as amended (the 1940 Act) and proposed to amend Form 13F to...more
On January 18, the Office of the Comptroller of the Currency (OCC) released its semiannual report on risks plaguing the federal banking system during Fall 2017. The report highlights the OCC's ongoing concerns for federal...more
In December 2016, Thomas Curry, the Comptroller of the Currency, stated that cybersecurity was the single greatest systemic threat to our financial system. He was not being hyperbolic. Cybersecurity should be on...more
As financial institutions of all sizes continue to face unprecedented cybersecurity risk, the Federal Financial Institutions Examination Council (FFIEC) released its Cybersecurity Assessment Tool. The Assessment is...more
Earlier this summer, the Federal Financial Institutions Examination Council (FFIEC) released its highly anticipated Cybersecurity Assessment Tool (Assessment), which is designed to assist financial institutions in identifying...more
The Federal Financial Institutions Examination Council (FFIEC) has recently developed a new tool to help U.S. financial institutions combat the increasing volume and sophistication of cyber attacks. To blunt threats to a...more