News & Analysis as of

Office of the Comptroller of the Currency Corporate Governance Financial Institutions

Orrick, Herrington & Sutcliffe LLP

OCC releases May 2025 enforcement actions

On May 15, the OCC announced enforcement actions against two banks and three institution-affiliated parties. The OCC issued cease and desist orders to banks in Miami, as well as Beverly Hills, California, respectively, for...more

Davis Wright Tremaine LLP

New Administration Outlook: FDIC Moves To Rescind Key, Controversial Proposals

The FDIC has signaled the reversal of key, controversial proposals from 2024. In doing so, it has provided welcome clarity on important areas that implicate banks of various sizes and charter types, allowing banks to focus on...more

Troutman Pepper Locke

Patriot Bank and OCC Sign Agreement to Strengthen Oversight and Payment Activities

Troutman Pepper Locke on

On January 14, Patriot Bank, N.A. entered into an agreement with the Office of the Comptroller of the Currency (OCC) to address and rectify several unsafe or unsound practices and violations of law. This agreement follows the...more

Troutman Pepper Locke

Federal and State Financial Agencies Issue Guidance on Elder Financial Exploitation

Troutman Pepper Locke on

Earlier this week, the Board of Governors of the Federal Reserve System (FRB), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Financial Crimes Enforcement Network (FinCEN), National...more

Latham & Watkins LLP

OCC, FRB, and FDIC Finalize Joint Principles for Climate-Related Financial Risk Management

Latham & Watkins LLP on

Guidance for the largest US financial institutions is intended to promote climate risk management consistent with general safety and soundness practices. On October 30, 2023, the three US federal bank regulatory agencies...more

Holland & Knight LLP

Agency Guidelines Confirm That Climate-Related Financial Risk Is Real

Holland & Knight LLP on

The U.S. Department of the Treasury's Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System (Board) and the Federal Deposit Insurance Corp. (FDIC) (collectively, the Agencies) on...more

Cadwalader, Wickersham & Taft LLP

OCC Issues Its Semiannual Risk Perspective

The Office of the Comptroller of the Currency (“OCC”) issued its Semiannual Risk Perspective for Spring 2022 on June 23. This was the same day the Federal Reserve released the results of its stress test for large bank holding...more

Sullivan & Worcester

Corporate Disclosures of Climate-Related Risks and Fulfilling Sustainability and Climate Commitments

Sullivan & Worcester on

Corporate disclosures regarding climate change impacts are becoming more prevalent, although not yet universal, and their adoption has been a relatively slow process. We discuss below the impact on corporations of increased...more

Mitratech Holdings, Inc

OCC Steps Up Scrutiny of EUCs at Financial Institutions

Mitratech Holdings, Inc on

EUCs – End User Computing applications – have hit the headlines again, after the US Office of the Comptroller of the Currency (OCC) levied a $400 million fine on an American-based bank. It found issues in the institution’s...more

Foodman CPAs & Advisors

While FinCEN lacks Independent Litigating Authority, it is the Regulator for the BSA and is responsible for the administration of...

FinCEN issues implementing regulations that “ensure” compliance with the BSA.  FinCEN delegates its examination authority to federal agencies.  These federal agencies are the “Federal Functional Regulators” who supervise...more

Troutman Pepper Locke

OCC Proposes Widespread Codification to Corporate Governance Rules for National Banks and Federal Associations

Troutman Pepper Locke on

The Office of the Comptroller of the Currency (“the OCC”) has issued a Notice of Proposed Rule Making (NPR) to revise and reorganize its regulations relating to the activities and operations of national banks and Federal...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

Bass, Berry & Sims PLC

New York and Feds Leading the Charge on Financial Institution Cybersecurity Regulations

Bass, Berry & Sims PLC on

Both federal and state officials recently proposed new regulations aimed at the financial sector in an effort to promote protection against high-impact technology failures and cyberattacks...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

Holland & Knight LLP

FFIEC’s Cybersecurity Assessment Tool: Guidance for CEOs and Boards - Senior Management and Boards Should Be Actively Addressing...

Holland & Knight LLP on

The Federal Financial Institutions Examination Council (FFIEC) released a Cybersecurity Assessment Tool (CAT) on June 30, 2015, to assist organizations in identifying cyber risks and assessing their cybersecurity...more

Goodwin

OCC Issues Final Guidelines Calling for Heightened Standards for Governance and Risk Management of Large Financial Institutions

Goodwin on

The OCC issued final guidelines (the “Final Guidelines”) that call for strengthened governance and risk management practices at the following categories of large financial institutions with $50 billion or more in average...more

Orrick - Finance 20/20

OCC Finalizes its Heightened Standards for Large Financial Institutions

On September 2, the OCC published final guidelines to strengthen the governance and risk management practices of large financial institutions. The guidelines apply to insured national banks, insured federal savings...more

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