News & Analysis as of

Banking Sector Financial Institutions Comptroller

Sheppard Mullin Richter & Hampton LLP

Senate Confirms Jonathan Gould as Comptroller of the Currency

On July 10, 2025, the U.S. Senate confirmed Jonathan Gould as Comptroller of the Currency in a 50–45 vote. Gould will serve a five-year term and returns to the OCC, where he previously served as Chief Counsel and Senior...more

Husch Blackwell LLP

New Exemption Order Creates More Flexibility and More Considerations with the Customer Identification Program Rule

Husch Blackwell LLP on

By an exemption order dated June 27, 2025, federal prudential regulators have given banks and credit unions some welcomed flexibility when collecting an individual’s or entity’s taxpayer identification number (TIN) during...more

Nutter McClennen & Fish LLP

Nutter Bank Report: May 2023

FDIC Announces Special Assessments to Recover Losses from Recent Bank Failures The FDIC has issued a proposed rule that would impose special assessments to recover the loss to the Deposit Insurance Fund (Fund) arising from...more

Latham & Watkins LLP

Acting Comptroller Confronts “Too Big to Manage” Issue

Latham & Watkins LLP on

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

Moore & Van Allen PLLC

Acting Comptroller Hsu Suggests a Potential Path Forward to Address Identified Gaps in the Regulatory Resolution Framework for...

Moore & Van Allen PLLC on

In the fourteen years since the 2008 financial crisis, significant actions have been taken by Federal banking agencies to make the largest financial institutions more resilient and less likely to fail and to require planning...more

Sheppard Mullin Richter & Hampton LLP

OCC: Crypto and DeFi Must Avoid Another Financial Crisis

Michael Hsu, the acting chief of the Office of the Comptroller of the Currency, recently addressed his remarks to the Blockchain Association drawing similarities between the current growth of cryptocurrencies and...more

Goodwin

FDIC Seeks Comment on Supervisory Approach to Examinations During Pandemic

Goodwin on

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

Goodwin

OCC Finalizes “True Lender” Rule

Goodwin on

In the News. The Office of the Comptroller of the Currency (OCC) finalized its “true lender” rule, which establishes that a national bank or federal savings association (bank) is the “true lender” of a loan if, as of the...more

Ballard Spahr LLP

Federal and State Banking Regulators Issue New Examination Procedures on Sampling Methodologies, UDAP/UDAAP, and CARES Act

Ballard Spahr LLP on

Recently, the federal banking regulators issued four new sets of examination procedures. The OCC issued two significant examination booklets on sampling methodologies and UDAP/UDAAP, and the federal banking regulators,...more

Kilpatrick

Acting Comptroller Explores the Separation of Banking and Commerce

Kilpatrick on

On November 8, Acting Comptroller of the Currency Keith A. Noreika explored how the separation of banking and commerce evolved in the United States and called for a broader discussion of whether the separation continues to...more

Tucker Arensberg, P.C.

The Office of the Comptroller of the Currency (“OCC”) has released Comptrollers Handbook A-DRCC, “Deposit Related Consumer...

Tucker Arensberg, P.C. on

The Office of the Comptroller of the Currency (“OCC”) has released Comptrollers Handbook A-DRCC, “Deposit Related Consumer Credit” (“DRCC”), as of February 2015. This Handbook discusses various types of small-dollar...more

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