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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
This second installment in a series of insights on bank charter considerations describes the consequences of operating through an insured depository institution charter, including capital requirements, supervision and...more
On November 10, the Fed released its biannual Supervision and Regulation Report ahead of congressional oversight hearings next week. The report covers banking system conditions, regulatory developments, and supervisory...more
Besides being a shock to the market, the 2023 bank failures caused many to ask whether the federal banking agencies had done enough to prevent them. Precisely what the agencies should have done, or should do moving forward,...more
As 2021 runs in search of what’s new, we realize that the pandemic disruption has continued through 2021. The NMLS Ombudsman Meeting was held virtually and the upcoming American Association of Residential Mortgage Regulators...more
The U.S. Office of the Comptroller of the Currency has announced updates to a number of supervision booklets, including the "Bank Supervision Process," "Community Bank Supervision," "Compliance Management Systems" and "Large...more
A new report issued by the federal Office of the Comptroller of the Currency (OCC) identifies top safety and soundness risks to national banks and federal savings associations, as well as OCC supervisory priorities for the...more
On January 27, 2015, the Consumer Financial Protection Bureau (“CFPB”) issued a compliance bulletin reminding supervised financial institutions (including large depository institutions, credit unions and their affiliates,...more
In updated examiner guidance and examination procedures issued last week, the Office of the Comptroller of the Currency (OCC) directs its examiners to assess whether the overdraft protection and other deposit-related consumer...more
In a new compliance bulletin (2015-01), the CFPB reminds supervised financial institutions, including nonbanks, of their obligations regarding the disclosure of confidential supervisory information (CSI)....more