News & Analysis as of

Office of the Comptroller of the Currency Regulatory Reform

Cadwalader, Wickersham & Taft LLP

Global Moves, Digital Shifts, July 2025 - Fed, FDIC and OCC Issue Proposed Rulemaking to Rescind 2023 CRA Rule

Last week, the Federal Deposit Insurance Corporation (“FDIC), Federal Reserve Board (“FRB”), and the Office of the Comptroller of the Currency (“OCC”) (collectively, “the Agencies”)  issued a proposed rulemaking to both...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

Cozen O'Connor

Passage of the GENIUS Act: A Turning Point in Stablecoin and Digital Asset Regulation

Cozen O'Connor on

President Donald J. Trump has signed into law the GENIUS Act (Guiding and Establishing National Innovation for U.S. Stablecoins of 2025 or the GENIUS Act of 2025), establishing the first comprehensive federal framework for...more

Vedder Price

OCC Ends Use of Disparate Impact in Fair Lending Supervision

Vedder Price on

The Office of the Comptroller of the Currency (“OCC”) has formally revised its fair lending examination procedures, announcing in Bulletin 2025-16, issued on July 14, 2025, that it has eliminated all references to disparate...more

Orrick, Herrington & Sutcliffe LLP

OCC removes reference to disparate impact for examiners

On July 14, the OCC announced it has removed the references to disparate impact liability from the “Fair Lending” booklet of the Comptroller’s Handbook and has started removing references in other issuances. The OCC has also...more

Vedder Price

Jonathan Gould Confirmed as Comptroller of the Currency

Vedder Price on

On Thursday, July 10, 2025, the U.S. Senate confirmed Jonathan Gould to serve as the next Comptroller of the Currency in a 50–45 vote. Gould will succeed Acting Comptroller Rodney Hood, who offered his congratulations and...more

Latham & Watkins LLP

Banking Regulators Propose to Ease Enhanced Supplementary Leverage Ratio for Large US Banks

Latham & Watkins LLP on

The proposal aims to free up large bank balance sheets and promote US Treasury market intermediation, which the current regulations may hinder....more

Skadden, Arps, Slate, Meagher & Flom LLP

The CIP Rule Gets an Upgrade: What Banks and Fintechs Need to Know About the New Exemption

Key Points - On June 27, 2025, the Federal Deposit Insurance Corporation (FDIC), the Office of Comptroller of the Currency (OCC) and the National Credit Union Administration (NCUA) exempted supervised banks and credit...more

Orrick, Herrington & Sutcliffe LLP

Prudential regulators propose rule on bank capital requirements

On June 27, the OCC, the Fed, and the FDIC issued a notice of proposed rulemaking to revise the enhanced supplementary leverage ratio standards for U.S. global systemically important banks (GSIBs) and their subsidiaries. The...more

Orrick, Herrington & Sutcliffe LLP

Agencies allow banks to access tax ID numbers from third parties

On June 27, the OCC, FDIC and NCUA, with the concurrence of FinCEN, granted an exemption allowing banks to use a third party source to obtain customer tax identification numbers (TIN) for customers before opening an account....more

Morgan Lewis

The Proposed GENIUS Act Raises Concerns Over Insolvency Provisions

Morgan Lewis on

Much attention has been paid to the regulatory and customer protection provisions of the proposed Guiding and Establishing National Innovation of US Stablecoins Act, the so-called GENIUS Act, S. 1582 (the proposed Act)....more

Mayer Brown Free Writings + Perspectives

US Banking Regulators Propose Enhanced Supplementary Leverage Ratio Reform

Last week, the US federal banking regulators proposed changes to the enhanced supplementary leverage ratio (“eSLR”) requirement for US global systemically important bank holding companies (“US GSIBs”) (the “Proposal”)....more

Ballard Spahr LLP

Financial institutions may rely on third parties for Social Security, Taxpayer Identification Numbers

Ballard Spahr LLP on

Banks and credit unions may now rely on third parties to provide a consumer’s Social Security or Taxpayer Identification Number, according to an order issued by the FDIC, OCC and the NCUA with the consent of the Financial...more

Orrick, Herrington & Sutcliffe LLP

Sen. Warren pens letter against removing the enhanced supplementary leverage ratio for banks

On June 23, the Ranking Member of the U.S. Senate Committee on Banking, Housing, and Urban Affairs, Sen. Elizabeth Warren (D-MA), penned a letter raising concerns over reports that the Fed, the FDIC, and the OCC intended to...more

Orrick, Herrington & Sutcliffe LLP

Fed announces that examination programs will no longer consider reputational risk

On June 23, the Fed announced it will no longer include reputational risk as a component of its examination programs in its supervision of banks. This move will align the Fed with the OCC, which made a similar announcement in...more

Perkins Coie

GENIUS Act Passes US Senate in Significant Step Towards Regulatory Clarity for Stablecoins

Perkins Coie on

The U.S. Senate passed the Guiding and Establishing National Innovation for U.S. Stablecoins Act or GENIUS Act (S.1582) (the Act) in a 68-30 bipartisan vote on June 17, 2025. The GENIUS Act would provide a clear regulatory...more

Sheppard Mullin Richter & Hampton LLP

Federal Reserve Board Removes Reputational Risk from Examination Ratings

On June 23, the Federal Reserve Board announced that reputational risk will no longer be a component of its bank-examination program. The same day, the Board released a revised edition of its Guidelines for Rating Risk...more

Cadwalader, Wickersham & Taft LLP

The Fine Print, June 2026 - Federal Banking Agencies Issue Proposed Rulemaking To Amend eSLR

This week, the Federal Reserve Board (“FRB") and the Office of the Comptroller of the Currency (“OCC”) issued a notice of proposed rulemaking (“NPR") to amend the Enhanced Supplementary Leverage Ratio (“eSLR”). At the time of...more

Ballard Spahr LLP

Fed to end use of reputational risk in examination programs

Ballard Spahr LLP on

The Federal Reserve Board has announced that it will eliminate reputational risk as a component of examination programs in its supervision of banks. ...more

McGuireWoods LLP

OCC Reaffirms that its National Bank Preemption Regulations are Lawful

McGuireWoods LLP on

On May 8, 2025, the Conference of State Bank Supervisors (“CSBS”) asked the Office of the Comptroller of the Currency (“OCC”) to comply with Executive Orders 14129 and 14267 by reversing its regulations governing national...more

Paul Hastings LLP

CLARITY and GENIUS Acts Advance, SEC DeFi Roundtable and OCC Agenda Drive Policy Momentum

Paul Hastings LLP on

The digital asset policy landscape developed on multiple fronts this week. The House Financial Services and Agriculture Committees voted to advance the CLARITY Act, a bipartisan proposal to establish a regulatory framework...more

Cadwalader, Wickersham & Taft LLP

Heating Up, June 2025 - OCC Defends Federal Bank Preemption

In response to a request from the Conference of State Bank Supervisors (“CSBS”), Acting Comptroller of the Currency, Rodney E. Hood, decisively defended OCC regulations regarding the ability of national banks and Federal...more

Orrick, Herrington & Sutcliffe LLP

OCC’s Hood remarks on building a “resurgent” financial system

On June 3, the OCC Acting Comptroller, Rodney E. Hood, delivered remarks outlining how he plans to build a resilient and resurgent financial system. The Acting Comptroller emphasized four key strategies: accelerating...more

Nutter McClennen & Fish LLP

Nutter Bank Report: May 2025

The FDIC and OCC have rescinded policy statements adopted in 2024 that changed the ways each agency considered bank merger transactions and have reinstated their prior procedures for evaluating bank mergers. The FDIC on May...more

Husch Blackwell LLP

DE&I Rollbacks: Are Banks in the Crosshairs?

Husch Blackwell LLP on

In January 2025, the new Trump administration issued Executive Order 14173, which ordered all executive departments and agencies to, among other things, end federal “diversity, equity, and inclusion” (DEI) programs and to use...more

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