News & Analysis as of

Office of the Comptroller of the Currency New Guidance Banking Sector

K&L Gates LLP

Federal Banking Regulators Adopt a Permissive Stance on Cryptocurrency

K&L Gates LLP on

The federal banking regulators have each recently adopted a more permissive approach to the regulation of cryptocurrency activities within the banking sector. The Office of the Comptroller of the Currency (OCC), the Federal...more

Ballard Spahr LLP

OCC, FDIC eliminating ‘reputational risk’ from supervision, examinations

Ballard Spahr LLP on

The OCC has removed “reputational risk” from its handbooks and guidance and the FDIC is moving to do the same. ...more

King & Spalding

OCC Clarifies Crypto-Asset Guidance

King & Spalding on

The Office of the Comptroller of the Currency (“OCC”) and the Federal Deposit Insurance Corporation (“FDIC”) have both recently taken actions and issued statements that indicate a more permissive bank regulatory approach to...more

Jones Day

FDIC Rescinds Prior Notification Requirement for Banks' Permissible Crypto Activities

Jones Day on

The FDIC has rescinded an earlier Financial Institution Letter establishing a prior notification requirement for FDIC-supervised institutions that wish to engage in specified crypto-related activities and has clarified that...more

Latham & Watkins LLP

FDIC Removes Roadblocks to Crypto Activities in the Banking Sector

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New FDIC guidance permits crypto activities by supervised institutions without prior approval, emphasizing risk management and compliance with applicable laws and regulations....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

Moore & Van Allen PLLC

OCC Revises Recovery Planning Guidelines for Large Banks

Moore & Van Allen PLLC on

On October 21, 2024, the Office of the Comptroller of the Currency (OCC) finalized revisions to its Guidelines Establishing Standards for Recovery Planning by Certain Large Insured National Banks, Insured Federal Savings...more

Sheppard Mullin Richter & Hampton LLP

OCC Issues Guidance on Refinance Risk in Commercial Lending

On October 3, the OCC issued Bulletin 2024-29, providing guidance for managing credit risk in connection with refinancing commercial loans.  The bulletin is directed at all banks with commercial loan portfolios, and...more

Venable LLP

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

Venable LLP on

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

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - February 2024

The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more

Latham & Watkins LLP

OCC Issues Policy Guidance on Venture Loans

Latham & Watkins LLP on

The OCC outlines safety and soundness principles and appropriate risk management processes for its regulated institutions that engage in venture lending. On November 1, 2023, the Office of the Comptroller of the Currency...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

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

Goodwin

Bank Regulators Issue Guidance for Third-Party Risk Management

Goodwin on

On June 6, 2023, the Board of Governors of the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, Agencies)...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

Jenner & Block

Client Alert: Bank-Fintech Partnerships Update: Banking Agencies Finalize Key Risk Management Guidance

Jenner & Block on

On June 6, 2023, federal banking agencies issued final Interagency Guidelines on Third-Party Relationships detailing their expectations for banks in establishing risk management practices with third-parties—including...more

Sheppard Mullin Richter & Hampton LLP

FDIC, FRB & OCC Issue Final Guidance on Risk Management for Third-Party Relationships

On June 6, the FDIC, FRB & OCC issued final interagency guidance intended to assist their respective supervised banking organizations in identifying and managing risks associated with third-party relationships and in...more

Goodwin

Overdraft Protection Programs: Risk Management Practices

Goodwin on

Regulatory Developments - Overdraft Protection Programs: Risk Management Practices - On April 26, the OCC issued guidance in OCC Bulletin 2013-12, “Overdraft Protection Programs: Risk Management Practices,” to...more

Nutter McClennen & Fish LLP

Nutter Bank Report: June 2022

Headlines - ..FDIC Proposes Substantial Increase in Deposit Insurance Assessment Rates ..Federal Reserve Releases New CECL Implementation Tool: Expected Losses ..Estimator OCC Report Highlights Risks Facing the Federal...more

Nutter McClennen & Fish LLP

Nutter Bank Report: May 2022

Federal Banking Agencies Issue CRA Modernization Proposal The federal banking agencies have jointly issued a proposed rule that would modernize their regulations that implement the Community Reinvestment Act (the “CRA”). The...more

Mitratech Holdings, Inc

US Regulators Raise Expectations of Third-Party Risk Management

Mitratech Holdings, Inc on

It takes something significant for all the US Banking Regulators – the Federal Reserve, the Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC) – to come together to pool...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

Nutter McClennen & Fish LLP

Nutter Bank Report: July 2021

CFPB Amends Mortgage Rule to Protect Borrowers Affected by COVID-19 The CFPB issued a final rule to amend its Regulation X—which implements the Real Estate Settlement Procedures Act—to assist home mortgage loan borrowers...more

Goodwin

Treasury Rolls Out Emergency Capital Investment Program

Goodwin on

In this Issue. The U.S. Department of the Treasury announced that it was opening the application process for the Emergency Capital Investment Program, a new program designed to provide long-term, low-cost equity and...more

Goodwin

SBA and Treasury Department Issue New Guidance on PPP

Goodwin on

In this Issue. The Office of the Comptroller of the Currency (OCC) issued guidance on its authority to charter limited purpose trust companies, raising the possibility that a limited purpose national bank could be organized...more

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