News & Analysis as of

Banking Sector Financial Institutions Government Agencies

Ballard Spahr LLP

FDIC proposes to replace Supervision Appeals Review Committee with an independent office

Ballard Spahr LLP on

The FDIC is proposing to replace its Supervision Appeals Review Committee (SARC) with an independent, standalone office, known as the Office of Supervisory Appeals (OSA). Under the proposal, the OSA would be the final level...more

Orrick, Herrington & Sutcliffe LLP

OCC’s new comptroller of the currency is Jonathan Gould

On July 15, the OCC announced that Jonathan V. Gould has taken office as the 32nd comptroller of the currency, following his nomination by President Donald J. Trump on February 11 and confirmation by the U.S. Senate on July...more

Orrick, Herrington & Sutcliffe LLP

OCC releases June 2025 enforcement actions

On June 18, the OCC announced enforcement actions against national banks, federal savings associations, and individuals currently or previously affiliated with supervised institutions. The OCC entered into three agreements...more

Orrick, Herrington & Sutcliffe LLP

Fed announces that examination programs will no longer consider reputational risk

On June 23, the Fed announced it will no longer include reputational risk as a component of its examination programs in its supervision of banks. This move will align the Fed with the OCC, which made a similar announcement in...more

Kohrman Jackson & Krantz LLP

Unclaimed Funds in Ohio: Is the State Holding Money that Belongs to You?

The Ohio Department of Commerce’s Division of Unclaimed Funds is safeguarding approximately $4 billion in unclaimed assets. In 2024, the Ohio Department of Commerce received $525 million in unclaimed funds but only $149...more

Sheppard Mullin Richter & Hampton LLP

OCC Rejects Calls to Roll Back Preemption Rules

On June 9, Acting Comptroller of the Currency Rodney Hood issued a letter rejecting the Conference of State Bank Supervisors’ (CSBS) request that the OCC rescind its 2011 preemption regulations. The OCC ‘s letter signals...more

Orrick, Herrington & Sutcliffe LLP

FDIC rescinds its bank merger policies in favor of previous one

On May 20, the FDIC announced its intent to rescind the 2024 Statement of Policy and reinstate its prior Bank Merger Statement of Policy. This decision reflected the FDIC’s assessment that the 2024 Statement of Policy added...more

Sheppard Mullin Richter & Hampton LLP

Senate Advances Stablecoin Bill

On May 20, the U.S. Senate voted 66-32 to move forward with the Guardrails and Enforcement for Neutral Issuers of United States Stablecoins (GENIUS) Act (the “Act”), pushing the stablecoin bill past a major procedural hurdle....more

Orrick, Herrington & Sutcliffe LLP

NCUA board members challenge unprecedented removal by President Trump

On April 28, a complaint was filed in the U.S. District Court for the District of Columbia, challenging the removal of two Senate-confirmed members of the NCUA Board by President Trump. The plaintiffs allege that their...more

Orrick, Herrington & Sutcliffe LLP

Senate committee seeks information on DOGE’s impact at FDIC

On April 24, four members of the U.S. Senate Committee on Banking, Housing, and Urban Affairs sent a letter to the FDIC requesting information regarding DOGE’s involvement at the FDIC. The senators are seeking information...more

Orrick, Herrington & Sutcliffe LLP

OCC announces changes to its organizational structure

On April 16, the OCC announced several changes to its organizational structure to align its supervisory approach to the agency’s priorities. The OCC announced the combination of the Midsize and Community Bank Supervision and...more

Orrick, Herrington & Sutcliffe LLP

NYDFS seeks to hire displaced federal financial employees amidst Trump administration cuts

On March 11, the Superintendent of NYDFS, Adrienne Harris, reportedly announced her agency’s intention to hire federal financial agency employees affected by recent job cuts under the Trump administration. Harris highlighted...more

Orrick, Herrington & Sutcliffe LLP

FDIC OIG responds to senators’ letter on FDIC bank examiners

On February 19, the Office of Inspector General (OIG) for the FDIC responded to a letter from Sen. Elizabeth Warren (D-MA) and others concerning the FDIC’s decision to rescind over 200 jobs for bank examiners. As previously...more

Orrick, Herrington & Sutcliffe LLP

Jonathan Gould nominated to be Comptroller of the Currency

On February 11, the White House announced Jonathan Gould’s nomination as Comptroller of the Currency. Recently, Rodney E. Hood was named Acting Comptroller of the Currency effective February 10....more

Skadden, Arps, Slate, Meagher & Flom LLP

Supreme Court Opens the Door to More Rule Challenges by Extending Accrual Date for APA Cases

In Corner Post v. Board of Governors of the Federal Reserve System, the U.S. Supreme Court held the six-year statute of limitations under 28 U.S.C. §2401 for challenging federal agency action under the Administrative...more

Sheppard Mullin Richter & Hampton LLP

Federal Agencies Request Comments on Risk Management Guidance for Third-Party Relationships

On July 13, the Federal Reserve, FDIC, and OCC proposed risk management guidance to help banking organizations manage risks related to third-party relationships, including relationships with vendors, FinTech companies,...more

Bradley Arant Boult Cummings LLP

Financial Services Licensing and Compliance Obligations and COVID-19

As members of the financial industry prepare to meet the challenges associated with COVID-19, key government agencies have begun to offer guidance with respect to how their regulated financial institutions, including...more

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