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Consumer Finance Monitor Podcast Episode: Regulating Bank Reputation Risk
In a significant shift, each of the country's three federal bank regulatory agencies have announced they will no longer consider reputational risk as a stand-alone supervisory category. Originally published in Law360 -...more
The Office of the Comptroller of the Currency (“OCC”) has formally revised its fair lending examination procedures, announcing in Bulletin 2025-16, issued on July 14, 2025, that it has eliminated all references to disparate...more
On Thursday, July 10, 2025, the U.S. Senate confirmed Jonathan Gould to serve as the next Comptroller of the Currency in a 50–45 vote. Gould will succeed Acting Comptroller Rodney Hood, who offered his congratulations and...more
Key Points - On June 27, 2025, the Federal Deposit Insurance Corporation (FDIC), the Office of Comptroller of the Currency (OCC) and the National Credit Union Administration (NCUA) exempted supervised banks and credit...more
On June 27, the OCC, the Fed, and the FDIC issued a notice of proposed rulemaking to revise the enhanced supplementary leverage ratio standards for U.S. global systemically important banks (GSIBs) and their subsidiaries. The...more
Last week, the US federal banking regulators proposed changes to the enhanced supplementary leverage ratio (“eSLR”) requirement for US global systemically important bank holding companies (“US GSIBs”) (the “Proposal”)....more
On June 23, the Ranking Member of the U.S. Senate Committee on Banking, Housing, and Urban Affairs, Sen. Elizabeth Warren (D-MA), penned a letter raising concerns over reports that the Fed, the FDIC, and the OCC intended to...more
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
The U.S. Senate passed the Guiding and Establishing National Innovation for U.S. Stablecoins Act or GENIUS Act (S.1582) (the Act) in a 68-30 bipartisan vote on June 17, 2025. The GENIUS Act would provide a clear regulatory...more
On June 23, the Federal Reserve Board announced that reputational risk will no longer be a component of its bank-examination program. The same day, the Board released a revised edition of its Guidelines for Rating Risk...more
This week, the Federal Reserve Board (“FRB") and the Office of the Comptroller of the Currency (“OCC”) issued a notice of proposed rulemaking (“NPR") to amend the Enhanced Supplementary Leverage Ratio (“eSLR”). At the time of...more
On May 8, 2025, the Conference of State Bank Supervisors (“CSBS”) asked the Office of the Comptroller of the Currency (“OCC”) to comply with Executive Orders 14129 and 14267 by reversing its regulations governing national...more
On June 3, the OCC Acting Comptroller, Rodney E. Hood, delivered remarks outlining how he plans to build a resilient and resurgent financial system. The Acting Comptroller emphasized four key strategies: accelerating...more
On April 24, the Federal Reserve withdrew its prior guidance for banks related to their crypto-asset and dollar token activities and also announced related changes to its expectations for these activities....more
On May 20, federal merger policy took a sharp turn as the FDIC voted to rescind its 2024 merger guidelines, and the U.S. House passed a Congressional Review Act (CRA) resolution to repeal the OCC’s 2024 merger rule....more
On May 8, Acting Comptroller of the Currency Rodney E. Hood spoke on his four priority areas: financial inclusion, reducing regulatory burdens, bank-fintech partnerships, and digital assets. He emphasized that financial...more
The current administration has indicated an intention for the U.S. to be a leader in the cryptocurrency industry, as discussed in the recent webcast Bank Regulatory Agency Update Under DOGE: What Every Financial Institution...more
The Office of the Comptroller of the Currency (OCC) has issued an interim final rule that restores streamlined and expedited regulatory procedures to review applications under the Bank Merger Act for business combinations...more
On May 8, 2025, the Office of the Comptroller of the Currency (OCC) announced its adoption of an interim final rule (IFR) that amends its 2024 final rule related to its regulations for business combinations involving national...more
This regular publication from DLA Piper focuses on helping banking and financial services clients navigate the ever-changing regulatory landscape....more
The federal banking regulators have each recently adopted a more permissive approach to the regulation of cryptocurrency activities within the banking sector. The Office of the Comptroller of the Currency (OCC), the Federal...more
FRB eases crypto restrictions on supervised entities in alignment with the new administration’s support for the digital asset industry....more
The Federal Reserve has announced multiple decisions to rescind existing requirements for crypto-asset activities. The April 24 announcement included the rescission of a 2022 supervisory letter that required state member...more
The OCC has removed “reputational risk” from its handbooks and guidance and the FDIC is moving to do the same. ...more
In April 2025, both the Consumer Financial Protection Bureau (CFPB) and the Office of the Comptroller of the Currency (OCC) announced significant changes to their supervisory and enforcement approaches, signaling a shift in...more