News & Analysis as of

Office of the Comptroller of the Currency Supervisory Guidance Financial Services Industry

Ballard Spahr LLP

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

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

Bradley Arant Boult Cummings LLP

A Closer Look at the CFPB’s “Enhanced” Supervisory Appeals Process

On February 16, 2024, the Consumer Financial Protection Bureau (CFPB) announced what it heralded as a significant update to its Supervisory Appeals Process. The first of its kind since 2015, this revision introduced a...more

Ballard Spahr LLP

Credit unions should expect increased supervision from NCUA on overdraft/NSF fees, vendor risk, and fair lending

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On February 6, 2024, National Credit Union Administration (NCUA) Chairman Todd M. Harper spoke at a Brookings Institution event to outline his regulatory agenda and supervisory priorities for 2024. His prepared remarks...more

Jones Day

Final Climate Risk Guidance Ensures Supervisory Focus from Banking Agencies in 2024

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The Situation: In October 2023, the Office of the Comptroller of the Currency ("OCC"), Federal Reserve System, and Federal Deposit Insurance Corporation ("FDIC," and the three agencies collectively, "Agencies") finalized...more

Ballard Spahr LLP

OCC issues bank supervision operating plan for fiscal year 2024

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The Office of the Comptroller of the Currency’s (OCC) Committee on Bank Supervision (CBS) recently issued its annual Bank Supervision Operating Plan for FY 2024, which sets forth the OCC’s supervision priorities and...more

Ballard Spahr LLP

Federal Reserve Board issues letters on program to supervise novel banking activities

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Earlier this month, the Federal Reserve Board (FRB) released two supervision and regulation letters regarding the agency’s program to supervise “novel” banking activities....more

Ballard Spahr LLP

Minnesota Bankers Association and Lake Central Bank sue FDIC over NSF fee guidance

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A complaint filed on July 20, 2023 in Minnesota federal court seeks declaratory and injunctive relief under the Administrative Procedures Act (APA) against defendants Federal Deposit Insurance Corporation (FDIC) and Chairman...more

Troutman Pepper Locke

OCC Senior Deputy Comptroller for Large Bank Supervision Provides Insight on Impact to Community Banks of the OCC’s Principles for...

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On July 18, Office of the Comptroller of the Currency (OCC) Senior Deputy Comptroller for Large Bank Supervision Greg Coleman testified on OCC supervision of climate-related financial risks before the U.S. House of...more

Goodwin

Biden Administration Issues Regulatory Freeze On New Agency Rules

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In this Issue. In one of its first acts after being installed on January 20, the Biden Administration issued a regulatory freeze on new agency rules that have been adopted but are not yet effective; in one of its final acts...more

Goodwin

OCC Proposes Rules for CRA Benchmarks and Fair Access

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In the News. The Office of the Comptroller of the Currency (OCC) issued a long-awaited rule seeking comment on its proposed approach to determine the Community Reinvestment Act (CRA) evaluation measure benchmarks, retail...more

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