News & Analysis as of

Banks Depository Institutions Office of the Comptroller of the Currency

Latham & Watkins LLP

Banking Regulators Propose to Ease Enhanced Supplementary Leverage Ratio for Large US Banks

Latham & Watkins LLP on

The proposal aims to free up large bank balance sheets and promote US Treasury market intermediation, which the current regulations may hinder....more

Goodwin

Regulatory Process for Forming or Acquiring a Depository Institution

Goodwin on

This third installment in our series of insights on bank charter considerations describes the process for seeking regulatory approval to form or acquire a bank....more

Troutman Pepper Locke

OCC Ceases Examinations for Reputation Risk Following Legislative Push

Troutman Pepper Locke on

On March 20, the Office of the Comptroller of the Currency (OCC) announced that it will no longer examine its regulated institutions for reputation risk. According to the OCC’s “Categories of Risk,” reputation risk is the...more

Nutter McClennen & Fish LLP

Nutter Bank Report: October 2024

The CFPB has approved a final rule that requires banks and certain other financial services providers to share a consumer’s personal financial data with another provider at the consumer’s request. The CFPB’s Personal...more

Paul Hastings LLP

Ch…Ch…Ch…Changes for Reviewing Bank Mergers Adopted

Paul Hastings LLP on

On September 17, 2024, the Federal Deposit Insurance Corporation (“FDIC”) and the Office of the Comptroller of the Currency (“OCC”) issued final “statements of policy” for transactions subject to the Bank Merger Act (“BMA”)....more

Mayer Brown

FDIC Issues Narrow Interpretation of ATM Exception in Definition of Domestic Branch

Mayer Brown on

On August 9, 2024, the US Federal Deposit Insurance Corporation (FDIC) issued an interpretation of the exclusion of automated teller machines (ATMs) and remote service units (RSUs) from the definition of a domestic branch....more

Latham & Watkins LLP

FDIC Proposes Amendments to Its Change in Bank Control Act Regulations

Latham & Watkins LLP on

The proposal would establish stricter oversight of certain transactions and responds to concerns that large asset managers may be exerting influence on FDIC-supervised institutions. On July 30, 2024, the Board of...more

Orrick, Herrington & Sutcliffe LLP

Bank regulators appeal to 5th Circuit to lift district court’s final rule ban

On July 18, the OCC, FDIC, and the Fed (the federal banking agencies or FBAs) submitted a brief requesting that the U.S. Court of Appeals for the Fifth Circuit hold oral argument and reverse the U.S. District Court for the...more

Venable LLP

FDIC Finalizes Large Bank Resolution Plan Rule and OCC Proposes Changes to Recovery Plans

Venable LLP on

The FDIC recently finalized its resolution planning rule for large banks, which becomes effective October 1, 2024. Resolution plans, or "living wills," are plans to wind down operations in the event of bank failures. The...more

Pillsbury - Global Sourcing Practice

Operational Resilience Requirements May Be Coming for Large U.S. Banks Soon

On March 12, 2024, Acting Comptroller of the Currency Michael Hsu indicated in a speech that regulations may soon be forthcoming that would be designed to bolster larger depository institutions’ ability to withstand...more

Cadwalader, Wickersham & Taft LLP

FRB, FDIC, OCC and NCUA Testify at Congressional Oversight Hearings

This week, the Senate Banking Committee and the House Financial Services Committee held oversight hearings with leaders of the Federal Deposit Insurance Corporation (“FDIC”), Federal Reserve Board (“FRB”), the National Credit...more

Polsinelli

Silicon Valley Bank Receivership

Polsinelli on

1. What happened Friday? a. The California Department of Financial Protection and Innovation closed Silicon Valley Bank (SVB) and appointed FDIC as receiver....more

Goodwin

OCC Seeks Feedback on Principles for Climate-Related Financial Risk Management

Goodwin on

In this Issue. The Office of the Comptroller of the Currency (OCC) is seeking feedback on principles for climate-related financial risk management for large banks; the Department of Justice’s Antitrust Division is seeking...more

Goodwin

Financial Services Weekly Roundup: Madden Fix/Valid When Made Rule Faces New Challengers

Goodwin on

In the News. On the heels of a lawsuit challenging the Office of the Comptroller of the Currency’s (OCC) recently issued Madden fix/valid when made rule, eight state attorneys general filed suit challenging a similar rule...more

BCLP

2019 Banking Landscape – Charter Types

BCLP on

Whenever discussing bank charter types, I’m reminded of a comparison made by Walt Moeling. Walt would always say that the bank charter choice is like choosing between a Ford and a Chevy truck. There are strong, die-hard...more

Ruder Ware

Expanded Examination Cycle

Ruder Ware on

The OCC, the Board of Governors of the Federal Reserve System, and the FDIC published an interagency interim final rule effective August 29, 2018. The interim final rule amends the regulations governing eligibility for an...more

A&O Shearman

Two US Banking Regulators Propose Amendments to Supplementary Leverage Ratio Calculations for GSIBs and Their Insured Depository...

A&O Shearman on

The U.S. Board of Governors of the Federal Reserve System and U.S. Office of the Comptroller of the Currency published a joint notice of proposed rulemaking and request for comment that would modify the calculation of the...more

Troutman Pepper Locke

Update: Prudential Regulators Delay Compliance Deadline for New Swap Margin Rules

Troutman Pepper Locke on

If you have been following our alerts on the pending deadlines (and the delays of these deadlines by certain regulators) of the new swap variation margin rules (New Swap Margin Rules) that were due to go into effect on March...more

Davis Wright Tremaine LLP

Federal Banking Agencies Seek Comment on Enhanced Cyber Risk Management Standards for Large Banks

To address the increasing risk of technology failures and cyber-attacks affecting the largest banking organizations, an advance notice of proposed rulemaking titled Enhanced Cyber Risk Management Standards (the ANPR) was...more

Alston & Bird

Federal Banking Agencies Issue Dodd–Frank Mandated Report on Bank Activities and Investments

Alston & Bird on

On September 8, 2016, the Board of Governors of the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) issued a 107-page joint...more

Ballard Spahr LLP

OCC Report Identifies Risks to Banks, Sets Supervisory Priorities

Ballard Spahr LLP on

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

Ballard Spahr LLP

OCC Updated Examiner Guidance Includes New Overdraft Protection Program Requirements

Ballard Spahr LLP on

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

Stinson - Corporate & Securities Law Blog

OCC Specifies ‘Heightened Expectations’ for Board of Director Oversight Responsibilities for Large Banks

The Office of the Comptroller of the Currency, or OCC, has adopted guidelines, issued as an appendix to its safety and soundness standards regulations, establishing minimum standards for the design and implementation of a...more

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