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Latham & Watkins LLP

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

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

Nutter McClennen & Fish LLP

Nutter Bank Report: March 2025

The federal banking agencies have announced their intent to issue a proposal to rescind the Community Reinvestment Act (CRA) final rule originally issued in October 2023. In their announcement on March 28, the agencies also...more

Moore & Van Allen PLLC

Developments in National Bank Act (NBA) Preemption: Illinois’ Interchange Fee Prohibition Act is Held Preempted by the NBA; Ninth...

Moore & Van Allen PLLC on

For followers of developments related to National Bank Act (NBA) preemption and the United States Supreme Court’s related decision in Cantero v. Bank of America, N.A., 602 U.S. 205 (2024), the waning days of 2024 proved...more

Cadwalader, Wickersham & Taft LLP

Banking Regulators’ Request for Information on Bank-Fintech Arrangements

On July 25, 2024, the Fed, the OCC and the FDIC (the “Banking Regulators”) released a “Request for Information on Bank-Fintech Arrangements Involving Banking Products and Services Distributed to Consumers and Businesses” (the...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

Cadwalader, Wickersham & Taft LLP

Summer Regulatory Round-Up | July 2024

The banking regulators have not yet gone out on vacation, as demonstrated by this grab-bag of announcements, speeches, rules and guidance: Acting Comptroller of the Office of the Comptroller of the Currency (OCC),...more

Goodwin

10 Considerations for Fintechs Partnering with Community Banks

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As banking and technology become more integrated, banks are increasingly partnering with fintechs to expand their customer offerings. The rapid rise of these partnerships has generated questions for both banks and fintechs on...more

Cadwalader, Wickersham & Taft LLP

The U.S. Basel III Endgame Proposal: Update and Thoughts

On September 18, 2023, the U.S. Basel III Endgame proposal was published in the Federal Register. The comment period ended on January 16, 2024, with the banking regulators (the Federal Reserve, the OCC, and the FDIC) having...more

Venable LLP

Crystal Clear: New Guide on Third-Party Risk Management for Community Banks - and Others

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It is no secret that the Federal Reserve, the FDIC, and the OCC have zeroed in on banks' use of third parties for products, services, and other operations, the risks those arrangements may pose, and banks' responsibility to...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

Mayer Brown

Private Credit Reporting Requirements Proposed by US Banking Regulators

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On December 27, 2023, the US federal banking regulators proposed a new set of reporting requirements for bank loans and commitments to private credit lenders and intermediaries....more

Venable LLP

Financial Regulatory Reform Tracker - Anti-Tailoring Efforts

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Following the 2023 bank failures, the federal banking regulators (the Federal Reserve, the OCC, and the FDIC) have signaled that they are seeking to develop more stringent bank regulatory requirements for larger banking...more

Hudson Cook, LLP

Federal Bank Regulatory Agencies Issue Final Joint Guidance for Managing Third-Party Relationship Risks

Hudson Cook, LLP on

On June 6, 2023, the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, and the Office of the Comptroller of the Currency issued final joint guidance addressing bank management of...more

Nutter McClennen & Fish LLP

Nutter Bank Report: June 2023

The federal banking agencies have published new guidance to help banking organizations manage risks associated with third-party relationships, including relationships with financial technology (fintech) companies. The new...more

Pillsbury Winthrop Shaw Pittman LLP

Bank-Fintech Partnerships and Fair Lending: Top Areas at Risk for Government Scrutiny

The Federal Deposit Insurance Corporation (FDIC) recently published a consent order issued against Cross River Bank that alleged the bank’s fair lending program’s noncompliance and weaknesses in its oversight of fintech...more

Skadden, Arps, Slate, Meagher & Flom LLP

Recent Actions by the Fed Show Its Continued Cautious Approach to Cryptoasset Activities by Supervised Institutions

In the past year, the Board of Governors of the Federal Reserve System (the Board) Biden administration officials, and other U.S. banking regulators have repeatedly voiced growing concerns about certain cryptoasset...more

Buchalter

OCC Highlights Banks’ Compliance Staffing Issues, Even as Regulators Place More Compliance Demands on Banks and Place Executives...

Buchalter on

In its recent Semiannual Risk Perspective, the Office of the Comptroller of the Currency (OCC) has highlighted the difficulties banks face finding adequate numbers and quality of hires for compliance oversight. While there...more

Ballard Spahr LLP

Federal banking agencies Issue “Crypto Asset Roadmap” for 2022 guidance; OCC confirms prior interpretive letters on crypto (but...

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The Federal Reserve Board, FDIC, and OCC (collectively, the “Agencies”) issued on November 23 a short Joint Statement on Crypto-Asset Policy Sprint Initiative and Next Steps (“Joint Statement”), which announced – without...more

Seyfarth Shaw LLP

Federal Agencies Issue Guidance on Loan Modifications Relating to COVID-19

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On March 22, 2020, in response to the growing anticipation for loan modifications necessitated by the implications of the Coronavirus Disease 2019 (“COVID-19”), the Federal Reserve, Federal Deposit Insurance Corporation,...more

Herbert Smith Freehills Kramer

COVID-19 Update: Bank Regulators, Including the FDIC, Urge Financial Institutions To Collaborate With Pandemic-Affected Customers,...

On March 22, federal banking regulators, including the board of governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration, the Office of the...more

Ballard Spahr LLP

Response from community groups to OCC/FDIC joint CRA proposal

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While banks, community groups, and regulators all seem to agree that there is a need to reform the Community Reinvestment Act (the “CRA”), which was signed into law by Jimmy Carter back in 1977 and hasn’t received a major...more

Farella Braun + Martel LLP

What’s Privilege Got to Do With It? Practical Tips for Managing Bank Regulators Access to Attorney-Client Privileged Information

The attorney-client privilege, which prohibits the compelled disclosure of confidential communications between an attorney and their client, is enshrined in common law and statutory codes across the country. See, e.g., Cal....more

King & Spalding

Banking Regulators Invite Comment On Cybersecurity Standards For Large Banks

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On Thursday, October 20, the Federal Reserve, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation jointly issued an advance notice of proposed rulemaking, requesting comments on...more

Ballard Spahr LLP

OCC Report Identifies Risks to Banks, Sets Supervisory Priorities

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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

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