News & Analysis as of

Office of the Comptroller of the Currency Banking Sector Proposed Legislation

Holland & Knight LLP

Executive Order Briefing: Guaranteeing Fair Banking for All Americans

Holland & Knight LLP on

President Donald Trump on Aug. 7, 2025, signed an executive order (EO or order) titled "Guaranteeing Fair Banking for All Americans," which declares that no American should be denied access to financial services based on...more

Smith Anderson

Feds' Shift On Reputational Risk Raises Questions For Banks

Smith Anderson on

In a significant shift, each of the country's three federal bank regulatory agencies have announced they will no longer consider reputational risk as a stand-alone supervisory category. Originally published in Law360 -...more

Cadwalader, Wickersham & Taft LLP

New Regulatory Priorities Spring Into Focus, April 2025 - Stablecoin Bills Moving to the Floor of the Senate and the House

As of Wednesday, stablecoin bills in the House and the Senate have been voted out of committee and moved onto the floor of each house for a full vote....more

Sheppard Mullin Richter & Hampton LLP

OCC Eliminates “Reputational Risk” Category from Bank Supervision Criteria 

On March 20, the OCC announced that it will no longer treat reputation risk as a standalone category in its supervision of national banks and federal savings associations. The decision marks a dramatic shift in the agency’s...more

Davis Wright Tremaine LLP

Senate Moves To End "Operation Choke Point" De-Banking With New Bill—But More Protections Are Needed

Following a key hearing in February, Senate Banking Committee Chairman Tim Scott (R-SC) is seeking to protect financial freedom with the introduction of the Financial Integrity and Regulation Management (FIRM) Act. The...more

Nutter McClennen & Fish LLP

Nutter Bank Report: May 2021

Court Rules that Debt Collector Violated FDCPA with Communication to Dunning Vendor - A federal appellate court has recently ruled that a debt collector violated certain privacy requirements under the federal Fair Debt...more

Perkins Coie

The True Lender Rule: One Step Closer to Repeal

Perkins Coie on

The Office of the Comptroller of the Currency’s (the OCC) True Lender Rule is all but repealed. On May 11, 2021, the U.S. Senate voted to approve a joint resolution to repeal the True Lender Rule under the Congressional...more

Ballard Spahr LLP

Senate bill introduced to override Madden decision

Ballard Spahr LLP on

Democratic Senator Mark Warner has introduced a bill, S.1642, that would override the Second Circuit’s decision in Madden v. Midland Funding. (In Madden, the Second Circuit ruled that a nonbank that purchases loans from a...more

Ballard Spahr LLP

D.C. District Court Allows Payday Lenders’ Due Process Claims To Proceed In Case Against “Operation Choke Point”

Ballard Spahr LLP on

On July 5, 2017, the U.S. District Court for the District Columbia, in the lawsuit filed in 2014 challenging “Operation Choke Point” — a federal enforcement initiative involving various agencies, including the Consumer...more

Ballard Spahr LLP

Congressman introduces fintech bill

Ballard Spahr LLP on

Republican Congressman Patrick McHenry, Vice Chair of the House Financial Services Committee, has introduced the “Financial Services Innovation Act of 2016,” which is intended to provide a streamlined regulatory process for...more

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