News & Analysis as of

Office of the Comptroller of the Currency Loans Risk Management

Orrick, Herrington & Sutcliffe LLP

OCC reports improved mortgage performance in Q4 2024

On March 24, the OCC published its Mortgage Metrics Report for the fourth quarter of 2024. The Report analyzed the performance of first-lien residential mortgage loans serviced by seven national banks in the U.S. As of...more

Orrick, Herrington & Sutcliffe LLP

Prudential regulators release 2024 Shared National Credit report

On March 10, the FDIC, the Fed and the OCC published the 2024 Shared National Credit Program (SNC) report which highlighted that the overall SNC credit risk remains moderate — with a slight increase in the severity of risk...more

Orrick, Herrington & Sutcliffe LLP

California and federal financial regulatory agencies issue statement on California wildfires to guide financial institutions

On January 14, the DFPI, in collaboration with the FDIC, the Fed, the NCUA and the OCC (collectively, the “agencies”) issued a joint statement addressing the impact of the California wildfires and straight-line winds on...more

Moore & Van Allen PLLC

OCC Issues Guidance Reminding Banks of Risks Associated with Refinancing Commercial Loans

Moore & Van Allen PLLC on

With the amount of commercial real estate loans scheduled for maturity over the next several years expected to increase significantly, there is accompanying heightened risk that some borrowers may be unable to replace their...more

Ballard Spahr LLP

OCC issues guidance on managing risks associated with “buy now, pay later” lending

Ballard Spahr LLP on

The Office of the Comptroller of the Currency (OCC) has issued a bulletin (2023-37) that provides guidance on managing risks associated with “buy now, pay later” (BNPL) lending.  The BNPL loans addressed in the bulletin are...more

Sheppard Mullin Richter & Hampton LLP

OCC Issues Bulletin on Risks Related to Venture Lending

On November 1, the OCC issued Bulletin 2023-34 addressing the topic of “venture lending,” referred to as “commercial loans to early-, expansion-, and late-stage companies.” According to the Bulletin, venture lending is often...more

McGlinchey Stafford

Federal Agencies Issue Joint Policy Statement for Commercial Real Estate Loan Workouts

McGlinchey Stafford on

On June 29, 2023, the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, and National Credit Union Administration (the agencies) jointly issued...more

Troutman Pepper Locke

OCC Establishes New Third-Party Risk Management Expectations, Including for Bank Relationships With Marketplace Lenders

Troutman Pepper Locke on

The bulletin requires relationships between banks and marketplace lenders to be treated with the same rigor of due diligence and ongoing oversight as other relationships with third parties. On January 24, the Office of...more

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