News & Analysis as of

Department of Justice (DOJ) Financial Institutions Office of the Comptroller of the Currency

Morgan Lewis

Financial Institutions Face Investigations and Possible Referral to DOJ Based on Past ‘Debanking’ Practices

Morgan Lewis on

An executive order signed by the US president on August 7, 2025, titled Guaranteeing Fair Banking for All Americans, seeks to prohibit financial institutions from engaging in “debanking” practices, such as denying services or...more

Orrick, Herrington & Sutcliffe LLP

CFPB dismisses redlining case after asserting payments were made

On May 21, the CFPB and DOJ successfully filed a motion to dismiss with prejudice a case in the U.S. District Court for the Western District of Tennessee after noting the defendant paid its penalties. The dismissal ended a...more

Ballard Spahr LLP

FDIC proposing rescinding merger policy adopted in September

Ballard Spahr LLP on

The FDIC has proposed rescinding the agency’s 2024 Statement of Policy on Bank Merger Transactions. FDIC officials said at the time of issuance that the Statement of Policy addresses the scope of transactions that will be...more

Moore & Van Allen PLLC

The Desk: March Edition

In other news from last month, we found out that Brian Quintenz was nominated by President Trump to serve as the next CFTC Chair. See our synopsis on Quintenz below. If and when Quintenz is confirmed—TBD on when the Senate...more

Latham & Watkins LLP

FDIC, OCC Finalize Policy on Bank Merger Transactions

Latham & Watkins LLP on

Regulators seek to provide clarity and transparency on the bank merger review process, but changes may increase application complexity and unpredictability. Consistent with ongoing initiatives to strengthen US antitrust...more

Bradley Arant Boult Cummings LLP

TD Bank’s Historic $3.1B Money Laundering Settlement a Warning to All Financial Institutions

On October 10, 2024, Attorney General Merrick Garland announced that TD Bank agreed to pay over $1.8 billion in penalties to resolve the U.S. Department of Justice’s (DOJ) investigation into money laundering and Bank Secrecy...more

Lowenstein Sandler LLP

TD Bank to Pay Historic $3 Billion Over AML Compliance Violations

Lowenstein Sandler LLP on

On October 10, 2024, multiple U.S. federal and state agencies cumulatively fined a number of US based Toronto Dominion Bank subsidiaries (collectively, TD Bank or the Bank) more than $3 billion after finding that TD Bank...more

The Volkov Law Group

TD Bank Agrees to Pay Over $3 Billion for Systemic Violations of Bank Secrecy Act and Money Laundering Violations (Part I of IV)

The Volkov Law Group on

In yet another reminder of the scope of Justice Department enforcement powers, and an important demonstration of the risks of non-compliance, the Justice Department and relevant banking agencies announced a $3 billion...more

Thomas Fox - Compliance Evangelist

TD Bank: Part 1-Money Laundering and the China Syndrome

Last week, representatives of the US government announced one of the largest sets of fines and penalties for failures in anti-money laundering ever laid down. It involved TD Bank N.A. and TD Bank US Holding Company. It was...more

Paul Hastings LLP

Daily Financial Regulation Update -- Friday October 11

Paul Hastings LLP on

October 10, 2024- TD Bank N.A., the 10th largest bank in the United States, and its parent company TD Bank US Holding Company pleaded guilty and agreed to an aggregate of $3 billion in fines and penalties—$1.8 billion in...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

Nutter McClennen & Fish LLP

Nutter Bank Report: September 2024

The FDIC, OCC, and U.S. Department of Justice (DOJ) have coordinated the release of new policies that will govern each agency’s consideration of bank merger transactions. The FDIC and OCC each published final statements of...more

Alston & Bird

FDIC, OCC, and DOJ Update Guidance on Bank Merger Evaluations

Alston & Bird on

Last week, each of the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), and the Department of Justice Antitrust Division (DOJ) revised how they will review bank mergers. Our...more

Ballard Spahr LLP

FDIC, OCC and Justice Department update bank merger guidelines

Ballard Spahr LLP on

The FDIC, the OCC and the Justice Department earlier this month issued updated standards for bank mergers. The three agencies acted separately, although officials noted that they had worked with the other agencies involved....more

Brownstein Hyatt Farber Schreck

Regulators Finalize New Approach to Bank Mergers

On Sept. 17, 2024, the Federal Deposit Insurance Corporation (FDIC) Board met to finalize an updated approach to increase scrutiny of bank mergers, particularly those that would result in a bank with over $100 billion in...more

BakerHostetler

DOJ Withdraws 1995 Bank Merger Guidelines as FDIC, OCC Make Regulatory Changes

BakerHostetler on

On September 17, 2024, the Department of Justice Antitrust Division (DOJ) shut the vault doors on its 1995 Bank Merger Guidelines, leaving the 2023 Merger Guidelines as its sole authoritative statement on the topic of mergers...more

Orrick, Herrington & Sutcliffe LLP

DOJ announces its withdrawal from the 1995 Bank Merger Guidelines

On September 17, the DOJ announced its withdrawal from the 1995 Bank Merger Guidelines, stating the 2023 Merger Guidelines will be the only authoritative statement across all industries. This decision followed collaboration...more

Troutman Pepper Locke

Troutman Pepper Weekly Consumer Financial Services Newsletter - April 2024

Troutman Pepper Locke on

To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Jones Day

OCC Proposal and Policy Statement on Bank Mergers Could Freeze the Banking Industry in Place

Jones Day on

The Situation: On January 29, 2024, the Office of the Comptroller of the Currency ("OCC") requested comment on a proposed rule updating its bank merger rules and incorporating a policy statement (the "Proposal") on agency...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

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

Morrison & Foerster LLP

Financial Services Report - Winter 2021

Morrison & Foerster LLP on

Welcome to the Financial Services Report, holiday style! Banks and non-banks alike started early this year with additions and changes to their regulator stockings. The Senate confirmed Rohit Chopra as the new CFPB Director....more

Hudson Cook, LLP

CFPB Bites of the Month - November Top 10

Hudson Cook, LLP on

Each month, we host a 30-minute webinar outlining the month's key announcements and takeaways from the Consumer Financial Protection Bureau (CFPB) for financial services providers to consider. In this month's article, we...more

Morrison & Foerster LLP

Federal Agencies Announce Ramp-Up of Redlining Enforcement

Morrison & Foerster LLP on

The Department of Justice (DOJ) joined other federal agencies in announcing an increased focus on fair lending issues. On October 22, 2021, DOJ announced a new initiative to crack down on “modern-day” redlining. DOJ is...more

Sheppard Mullin Richter & Hampton LLP

CFPB, DOJ and OCC Take Action Against National Bank for Alleged Redlining

The CFPB and DOJ, in cooperation with the OCC, filed a complaint and proposed consent order last week in the Western District of Tennessee against a national bank alleging that the bank violated the Fair Housing Act (FHA),...more

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