News & Analysis as of

Comment Period Office of the Comptroller of the Currency

Troutman Pepper Locke

Federal Banking Agencies Propose Rescission of 2023 CRA Final Rule and Reinstatement of 1995 CRA Regulations

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On July 16, the Federal Reserve Board, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the federal banking agencies) jointly published a proposed rule...more

Mayer Brown Free Writings + Perspectives

US Banking Regulators Propose Enhanced Supplementary Leverage Ratio Reform

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

Orrick, Herrington & Sutcliffe LLP

GOP members of Financial Services Committee pen letter on bank-fintech partnerships

On October 30, Republican congressmembers serving on the U.S. House Committee on Financial Services responded to a joint Request for Information (RFI) issued by the OCC, the Fed and the FDIC. The RFI solicited input on...more

Ballard Spahr LLP

Bank Regulators Issue Statement on Third-Party Relationships with Financial Institutions and Publish Request for Information on...

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The federal banking regulators (The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation) issued on July 25 a lengthy joint statement...more

Latham & Watkins LLP

OCC Proposes Updates to Large Bank Recovery Planning Guidelines

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OCC-supervised institutions with $100 billion or more in average total consolidated assets must be adequately prepared to mitigate severe financial and non-financial risks. ...more

Venable LLP

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

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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

Troutman Pepper Locke

OCC Proposes Amendments to its Recovery Planning Guidelines

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On June 24, the Office of the Comptroller of the Currency (OCC) announced it is requesting comments on proposed amendments to its recovery planning guidelines. A recovery plan’s purpose is to provide a covered bank with a...more

Nutter McClennen & Fish LLP

Nutter Bank Report: April 2024

The CFPB has issued a policy statement that provides an analytical framework for identifying what constitutes an abusive act or practice under the Consumer Financial Protection Act of 2010 (CFPA). The new guidance published...more

Orrick, Herrington & Sutcliffe LLP

OCC extends comment period on proposed rules for the Bank Merger Act

On April 10, the OCC announced a notice published in the Federal Register extending the comment period for the OCC’s proposed rule on bank mergers. The NPRM titled, “Business Combinations under the Bank Merger Act,” was...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

FDIC Seeks to Restrict Noncompete Agreements in Bank Mergers

On March 21, 2024, the FDIC unveiled proposed revisions to its Statement of Policy (SOP) on Bank Merger Transactions, which was last amended in 2008. The revisions would increase scrutiny of bank mergers, particularly mergers...more

Troutman Pepper Locke

FDIC Proposes Increased Scrutiny of Bank Mergers

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Today, a divided Federal Deposit Insurance Corporation’s (FDIC) Board of Directors issued a proposed Statement of Policy (SOP) on bank merger transactions that would create a combined bank with more than $100 billion in...more

Orrick, Herrington & Sutcliffe LLP

Federal bank regulatory agencies seek comment on interagency effort to reduce regulatory burden

On February 6, the FDIC, Fed, and OCC initiated a series of requests for public comment aimed at reducing regulatory burden on supervised institutions. This effort is mandated by the Economic Growth and Regulatory Paperwork...more

Troutman Pepper Locke

OCC Proposes Rulemaking Amending Bank Merger Act Procedures to Eliminate Expedited and Streamlined Review and Add Policy Statement...

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On January 29, the Office of the Comptroller of the Currency (OCC) issued a notice of proposed rulemaking regarding its review of business combinations under the Bank Merger Act (BMA). Specifically, the OCC proposed: (i)...more

Nutter McClennen & Fish LLP

Nutter Bank Report: January 2024

OCC Requests Public Comments on Proposed Bank Merger Policy Statement and Rules The OCC has proposed a new policy to increase the transparency of the standards that the agency applies to review business combinations involving...more

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - November 2023

The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more

Orrick, Herrington & Sutcliffe LLP

Agencies extend comment period on proposed rules to strengthen large bank capital requirements

On October 20, the Fed issued a joint press release with the FDIC and the OCC announcing the extension of the comment period on proposed rules to expand large bank capital requirements. Earlier this year, the agencies...more

Goodwin

Federal Banking Agencies Propose Basel III Endgame Capital Rules

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On July 27, 2023, the Federal Reserve, FDIC, and OCC issued a notice of proposed rulemaking and request for comment on a proposal (the Proposal) to implement the final components of the Basel III Capital Accords, often...more

Orrick, Herrington & Sutcliffe LLP

Agencies propose Call Report revisions

On February 22, the FDIC, Federal Reserve Board, and the OCC announced the publication of a joint notice and request for comment proposing changes to three versions of the Call Report (FFIEC 031, FFIEC 041, and FFIEC 051)...more

Orrick, Herrington & Sutcliffe LLP

DOJ solicits additional comments on bank mergers

On December 17, the DOJ announced that its Antitrust Division is soliciting additional public comments regarding the potential revision of the 1995 Bank Merger Competitive Review Guidelines (Banking Guidelines) as part of a...more

Goodwin

Federal Reserve Invites Public Comment on Proposed Principles for Large Banking Organizations to Manage Climate-Related Financial...

Goodwin on

Regulatory Developments - Federal Reserve Invites Public Comment on Proposed Principles for Large Banking Organizations to Manage Climate-Related Financial Risks - On December 2, the Federal Reserve announced that it...more

Perkins Coie

Fintech Legal Report - November 2022

Perkins Coie on

FTC Action Against Internet Phone Service Provider Results in $100 Million to Customers Trapped by Illegal Dark Patterns and Junk Fees When Trying To Cancel Service - On November 3, 2022, the Federal Trade Commission (FTC)...more

Goodwin

Federal Reserve and FDIC Solicit Public Comments on Proposed Rulemaking Addressing Large Banks’ Financial Stability

Goodwin on

Regulatory Developments - Federal Reserve and FDIC Solicit Public Comments on Proposed Rulemaking Addressing Large Banks’ Financial Stability - On October 14, the Federal Reserve and the FDIC published for public...more

Cadwalader, Wickersham & Taft LLP

FRB Vice Chair Brainard Touts CRA Proposal and Positive Impacts on Native American Communities

On July 19, Federal Reserve Board (“FRB”) Vice Chair Lael Brainard gave remarks to the National Native Coalition Virtual Series sponsored by the National Congress of American Indians. Her remarks focused on the joint proposal...more

Paul Hastings LLP

Daily Financial Regulation Update -- Wednesday, July 13, 2022

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July 12, 2022- The U.S. Department of the Treasury released a notice seeking public comment regarding potential opportunities and risks presented by developments and adoption of digital assets as part of its work under...more

Cadwalader, Wickersham & Taft LLP

In Depth: A Look at Federal Banking Agencies’ Proposal to Update Community Reinvestment Act Rules

As we mentioned briefly in our newsletter last week, the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board (“FRB”)  and the Office of the Comptroller of the Currency (“OCC”) (together, “The Agencies”)...more

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