News & Analysis as of

Internal Controls Office of the Comptroller of the Currency Banking Sector

Nutter McClennen & Fish LLP

Nutter Bank Report: June 2025

The Federal Reserve has announced that the agency will no longer assess reputational risk when examining banks’ risk management processes. According to the June 23 announcement, the Federal Reserve has already begun reviewing...more

Latham & Watkins LLP

Acting Comptroller Confronts “Too Big to Manage” Issue

Latham & Watkins LLP on

The Acting Comptroller of the OCC discussed the limits of large bank manageability and the steps that regulators can take to address the risks posed by size and complexity. On January 17, 2023, Acting Comptroller of the...more

Holland & Knight LLP

The Impact of Cybersecurity Regulations on the Financial Services Industry in 2022

Holland & Knight LLP on

Following the SolarWinds and the Colonial Pipeline cyberattacks, the Biden Administration emphasized a shift toward mandatory cybersecurity requirements. Throughout 2021, government agencies issued new cybersecurity guidance,...more

Eversheds Sutherland (US) LLP

Federal Banking Regulators Shine Light Again on Third-Party Risk Management

Federal banking regulators have again demonstrated their focus on bank oversight and management of risk from third party relationships through a series of guidance and proposed guidance published in the third quarter of 2021....more

Moore & Van Allen PLLC

OCC Releases Bulletin on Fraud Risk Management Principles

In the aftermath of sales practices, the Office of the Comptroller of the Currency (OCC) recently published a bulletin on fraud risk management principles that are applicable to all federally chartered financial institutions....more

Vedder Price

The OCC Speaks: How FinTech Applications Will Be Reviewed

Vedder Price on

On March 15, 2017, the Office of the Comptroller of the Currency (the “OCC”) published for comment a draft supplement to the OCC’s existing Comptroller’s Licensing Manual providing detail on how the OCC will evaluate national...more

WilmerHale

OCC Revises CMP Policy

WilmerHale on

For the first time in over twenty years, the Office of the Comptroller of the Currency (OCC) has formally changed its policy governing civil money penalties (CMP) against national banks, federal savings associations, federal...more

Troutman Pepper

Observation 3.0: Frequently Asked Questions and Answers on the Volcker Rule and the Implications for Foreign Banks Investing in...

Troutman Pepper on

1. Question: What is the Volcker Rule, and when does it take effect? Answer: The Volcker Rule was enacted into law as section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank...more

Morrison & Foerster LLP - Structured Products

Structured Thoughts: News for the financial services community, Volume 6, Issue 6

U.S. Structured Warrant Programs: Introduction - U.S. and non-U.S. banks have offered structured warrants in the U.S. to address the needs of both institutional and high-net worth investors. This article will...more

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