News & Analysis as of

Financial Institutions Government Agencies Office of the Comptroller of the Currency

Orrick, Herrington & Sutcliffe LLP

OCC’s new comptroller of the currency is Jonathan Gould

On July 15, the OCC announced that Jonathan V. Gould has taken office as the 32nd comptroller of the currency, following his nomination by President Donald J. Trump on February 11 and confirmation by the U.S. Senate on July...more

Ballard Spahr LLP

Federal banking agencies seek information on actions to address payments fraud

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On June 20, 2025, the Office of the Comptroller of the Currency (OCC), Treasury, the Board of Governors of the Federal Reserve System (FRB), and the Federal Deposit Insurance Corporation (FDIC) announced they are seeking...more

Orrick, Herrington & Sutcliffe LLP

House Oversight Committee sends letter to OCC’s Hood on debanking documents

On June 25, the Chairman for the House Committee on Oversight and Government Reform, Rep. James Comer (R-KY), sent a letter to OCC Acting Comptroller Rodney Hood requesting documents and communications related to the...more

Orrick, Herrington & Sutcliffe LLP

OCC releases June 2025 enforcement actions

On June 18, the OCC announced enforcement actions against national banks, federal savings associations, and individuals currently or previously affiliated with supervised institutions. The OCC entered into three agreements...more

Orrick, Herrington & Sutcliffe LLP

Fed announces that examination programs will no longer consider reputational risk

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

Sheppard Mullin Richter & Hampton LLP

OCC Rejects Calls to Roll Back Preemption Rules

On June 9, Acting Comptroller of the Currency Rodney Hood issued a letter rejecting the Conference of State Bank Supervisors’ (CSBS) request that the OCC rescind its 2011 preemption regulations. The OCC ‘s letter signals...more

Orrick, Herrington & Sutcliffe LLP

OCC announces changes to its organizational structure

On April 16, the OCC announced several changes to its organizational structure to align its supervisory approach to the agency’s priorities. The OCC announced the combination of the Midsize and Community Bank Supervision and...more

Orrick, Herrington & Sutcliffe LLP

Jonathan Gould nominated to be Comptroller of the Currency

On February 11, the White House announced Jonathan Gould’s nomination as Comptroller of the Currency. Recently, Rodney E. Hood was named Acting Comptroller of the Currency effective February 10....more

Sheppard Mullin Richter & Hampton LLP

Federal Agencies Request Comments on Risk Management Guidance for Third-Party Relationships

On July 13, the Federal Reserve, FDIC, and OCC proposed risk management guidance to help banking organizations manage risks related to third-party relationships, including relationships with vendors, FinTech companies,...more

Ballard Spahr LLP

Diversity reports at two federal agencies offer glimpse of regulatory review under impending Dodd-Frank diversity standards

Ballard Spahr LLP on

The Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”), signed by President Obama in 2010 in response to the financial crisis, includes a provision intended to remedy racial and gender discrepancies at...more

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