News & Analysis as of

Office of the Comptroller of the Currency Depository Institutions

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

Goodwin

Federal Stablecoin Legislation Poised to Implement Comprehensive Regulatory Framework for Payment Stablecoins

Goodwin on

The Guiding and Establishing National Innovation for U.S. Stablecoins Act (the “GENIUS Act”), which would comprehensively regulate stablecoins in the United States, was adopted by the U.S. Senate on June 17 by a bipartisan...more

Fenwick & West LLP

U.S. Senate Passes the GENIUS Act - Stablecoin Legislation Moves to the House

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On June 17, 2025, the U.S. Senate passed S. 1582 (GENIUS Act) with bipartisan support (68–30), creating the first comprehensive federal framework for stablecoin regulation. This landmark legislation establishes clear...more

Goodwin

Regulatory Process for Forming or Acquiring a Depository Institution

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This third installment in our series of insights on bank charter considerations describes the process for seeking regulatory approval to form or acquire a bank....more

Stinson LLP

CFPB and OCC Signal Strategic Shifts in Supervision and Enforcement

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In April 2025, both the Consumer Financial Protection Bureau (CFPB) and the Office of the Comptroller of the Currency (OCC) announced significant changes to their supervisory and enforcement approaches, signaling a shift in...more

Troutman Pepper Locke

OCC Ceases Examinations for Reputation Risk Following Legislative Push

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On March 20, the Office of the Comptroller of the Currency (OCC) announced that it will no longer examine its regulated institutions for reputation risk. According to the OCC’s “Categories of Risk,” reputation risk is the...more

Nutter McClennen & Fish LLP

Nutter Bank Report: October 2024

The CFPB has approved a final rule that requires banks and certain other financial services providers to share a consumer’s personal financial data with another provider at the consumer’s request. The CFPB’s Personal...more

Paul Hastings LLP

Ch…Ch…Ch…Changes for Reviewing Bank Mergers Adopted

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On September 17, 2024, the Federal Deposit Insurance Corporation (“FDIC”) and the Office of the Comptroller of the Currency (“OCC”) issued final “statements of policy” for transactions subject to the Bank Merger Act (“BMA”)....more

Mayer Brown

FDIC Issues Narrow Interpretation of ATM Exception in Definition of Domestic Branch

Mayer Brown on

On August 9, 2024, the US Federal Deposit Insurance Corporation (FDIC) issued an interpretation of the exclusion of automated teller machines (ATMs) and remote service units (RSUs) from the definition of a domestic branch....more

Latham & Watkins LLP

FDIC Proposes Amendments to Its Change in Bank Control Act Regulations

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The proposal would establish stricter oversight of certain transactions and responds to concerns that large asset managers may be exerting influence on FDIC-supervised institutions. On July 30, 2024, the Board of...more

Orrick, Herrington & Sutcliffe LLP

Bank regulators appeal to 5th Circuit to lift district court’s final rule ban

On July 18, the OCC, FDIC, and the Fed (the federal banking agencies or FBAs) submitted a brief requesting that the U.S. Court of Appeals for the Fifth Circuit hold oral argument and reverse the U.S. District Court for the...more

Venable LLP

FDIC Finalizes Large Bank Resolution Plan Rule and OCC Proposes Changes to Recovery Plans

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The FDIC recently finalized its resolution planning rule for large banks, which becomes effective October 1, 2024. Resolution plans, or "living wills," are plans to wind down operations in the event of bank failures. The...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

Cadwalader, Wickersham & Taft LLP

FRB, FDIC, OCC and NCUA Testify at Congressional Oversight Hearings

This week, the Senate Banking Committee and the House Financial Services Committee held oversight hearings with leaders of the Federal Deposit Insurance Corporation (“FDIC”), Federal Reserve Board (“FRB”), the National Credit...more

Orrick, Herrington & Sutcliffe LLP

Agencies update guidance on liquidity risks and contingency planning

On July 28, the OCC, FDIC, NCUA and Fed issued an addendum to the Interagency Policy Statement on Funding and Liquidity Risk Management, issued in 2010. The update on liquidity risks and contingency planning emphasizes that...more

Troutman Pepper Locke

Federal Agencies Issue Joint Guidance on Contingency Planning for Liquidity Risks

Troutman Pepper Locke on

On July 28, the Board of Governors of the Federal Reserve System (Federal Reserve), Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, and the National Credit Union Administration (NCUA)...more

Polsinelli

Silicon Valley Bank Receivership

Polsinelli on

1. What happened Friday? a. The California Department of Financial Protection and Innovation closed Silicon Valley Bank (SVB) and appointed FDIC as receiver....more

Cadwalader, Wickersham & Taft LLP

Banking Agencies Extend Reg. O Relief

On December 22, just before many of us may have started turning to our holiday breaks, the Federal Reserve Board (“FRB”), Federal Deposit Insurance Corporation (“FDIC”) and Office of the Comptroller of the Currency (“OCC”)...more

McGlinchey Stafford

The Future of Minority Depository Institutions: An Update from the Office of the Comptroller of the Currency

McGlinchey Stafford on

On July 26, 2022, the Office of the Comptroller of the Currency (OCC) issued an update to its 2013 policy statement on minority depository institutions (MDIs). Changes to the policy statement include: (i) clarifying the...more

Goodwin

OCC Seeks Feedback on Principles for Climate-Related Financial Risk Management

Goodwin on

In this Issue. The Office of the Comptroller of the Currency (OCC) is seeking feedback on principles for climate-related financial risk management for large banks; the Department of Justice’s Antitrust Division is seeking...more

White & Case LLP

Unstable: the PWG's Report on Stablecoins

White & Case LLP on

On November 1, 2021, the President's Working Group on Financial Markets (the "PWG"), the Federal Deposit Insurance Corporation (the "FDIC") and the Office of the Comptroller of the Currency (the "OCC") issued a Report on...more

Morgan Lewis

President’s Working Group Report: Stablecoin Issuers Should Be Banks; Status as Securities or Commodities Still Unclear

Morgan Lewis on

US President Joe Biden’s Working Group on Financial Markets (PWG), along with the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC), released a report on the risks and...more

Goodwin

SEC Publishes Sample Climate Change Comment Letter

Goodwin on

In This Issue. The U.S. Securities and Exchange Commission (SEC) published a sample comment letter on climate change disclosures; the Financial Industry Regulatory Authority (FINRA) is conducting a review of brokerage firm...more

Goodwin

FDIC Seeks Comment on Supervisory Approach to Examinations During Pandemic

Goodwin on

In This Issue. The Federal Deposit Insurance Corporation (FDIC) is seeking information and comment regarding the FDIC’s supervisory approach to examinations during the pandemic; the FDIC’s tech lab, FIDTECH, announced a “tech...more

Goodwin

Second Circuit Orders Dismissal of Legal Challenge to Fintech Charter Program

Goodwin on

On June 3, 2021, the Second Circuit ruled that the New York State Department of Financial Services (DFS) lacked legal standing to challenge the Office of the Comptroller of the Currency’s (OCC’s) fintech charter program. The...more

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