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Ballard Spahr LLP

FDIC proposes to replace Supervision Appeals Review Committee with an independent office

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The FDIC is proposing to replace its Supervision Appeals Review Committee (SARC) with an independent, standalone office, known as the Office of Supervisory Appeals (OSA). Under the proposal, the OSA would be the final level...more

Troutman Pepper Locke

SEC Whistleblower Awards Face Scrutiny as Denials Rise

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A recent article by Bloomberg Law highlighted a significant shift in the Securities and Exchange Commission’s (SEC) approach to whistleblower claims. The article, “Whistleblower Awards Slow to Trickle as SEC Raises Bar on...more

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

Ballard Spahr LLP

FinCEN Delays And Intends To Revisit Investment Adviser Final Rule

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We blogged last year about the Final Rule issued by the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) extending Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT)...more

Smith Anderson

Feds' Shift On Reputational Risk Raises Questions For Banks

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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

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

Ballard Spahr LLP

Jonathan Gould confirmed as Comptroller of the Currency

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The Senate has confirmed Jonathan Gould as Comptroller of the Currency. Gould, who served as Senior Deputy Comptroller and Chief Counsel at the OCC during President Trump’s first term, was confirmed 50-45. Every Democrat...more

Ballard Spahr LLP

Federal banking agencies seek information on actions to address payments fraud

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On June 20, 2025, the Office of the Comptroller of the Currency (OCC), Treasury, the Board of Governors of the Federal Reserve System (FRB), and the Federal Deposit Insurance Corporation (FDIC) announced they are seeking...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

Moore & Van Allen PLLC

The Desk: July Edition

We hope everyone has a relaxing, safe, and enjoyable Fourth of July. Despite some personnel changes at the CFTC, the current administration seems to be hitting its stride in terms of enforcement actions and regulatory...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

Ballard Spahr LLP

Fed to end use of reputational risk in examination programs

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

Ballard Spahr LLP

NYC Comptroller calls for strengthening city, state consumer protection laws, regulations

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Accusing the Trump Administration of “dismantling” the CFPB, New York City Comptroller Brad Lander is calling on city and state officials to fill the void by strengthening consumer protection laws and rules in the city and...more

Mayer Brown

Brasília em Pauta – Edição Nº 204

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Prezados e prezadas, O “Brasília em Pauta” é um boletim semanal preparado pela equipe de Contencioso de Brasília, contendo os principais casos a serem julgados pelo Supremo Tribunal Federal (STF), Superior Tribunal de...more

Orrick, Herrington & Sutcliffe LLP

Financial services industry trade groups pen letter to Treasury Secretary Bessent on cybersecurity risks

On June 9, multiple financial services trade associations sent a letter to Treasury Secretary Scott Bessent expressing concerns about cybersecurity risk management practices at federal regulatory agencies following the OCC’s...more

Sheppard Mullin Richter & Hampton LLP

OCC Rejects Calls to Roll Back Preemption Rules

On June 9, Acting Comptroller of the Currency Rodney Hood issued a letter rejecting the Conference of State Bank Supervisors’ (CSBS) request that the OCC rescind its 2011 preemption regulations. The OCC ‘s letter signals...more

A&O Shearman

EBA speech on efficiency and effectiveness of EU Financial Regulation

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The European Banking Authority (EBA) has published a keynote speech delivered by its Chairperson, José Manuel Campa, at a high-level meeting for European supervisors in Ljubljana, Slovenia, on the importance of an efficient...more

Orrick, Herrington & Sutcliffe LLP

OCC releases its May 2025 CRA performance evaluations

On June 2, the OCC released a list of CRA performance evaluations that became public during the month of May. The OCC evaluated 18 banking entities, including national banks, federal savings associations, and insured federal...more

BakerHostetler

US Financial Regulators Chart New Path Forward for the Crypto Industry

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On April 24, the Federal Reserve withdrew its prior guidance for banks related to their crypto-asset and dollar token activities and also announced related changes to its expectations for these activities....more

Sheppard Mullin Richter & Hampton LLP

CFPB Director Nominee to Move to Treasury Finance Role

On May 9, the U.S. Department of the Treasury announced that President Trump intends to nominate Jonathan McKernan to serve as the Undersecretary of Domestic Finance. McKernan had been awaiting Senate confirmation to lead the...more

Amundsen Davis LLC

Banking Regulators Signal Change in Cryptocurrency Approach

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The current administration has indicated an intention for the U.S. to be a leader in the cryptocurrency industry, as discussed in the recent webcast Bank Regulatory Agency Update Under DOGE: What Every Financial Institution...more

Ballard Spahr LLP

Trump to nominate CFPB nominee to Treasury Department position

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Treasury Secretary Scott Bessent announced May 9 that President Trump intends to nominate Jonathan McKernan, his nominee to head the CFPB, as the Undersecretary of Domestic Finance at Treasury....more

Orrick, Herrington & Sutcliffe LLP

Democratic senators press CFPB’s Vought on mass firings

On April 28, Sen. Elizabeth Warren (D-MA), one of 40 democratic senators, sent a letter to CFPB Acting Director, Russell Vought, expressing their concerns about Vought’s attempt to terminate nearly all of the Bureau’s 1,700...more

Orrick, Herrington & Sutcliffe LLP

Democrats write to OIG on NCUA board member removals

On April 29, Sen. Elizabeth Warren (D-MA) and Rep. Maxine Waters (D-CA) sent a letter to the Inspector General of the NCUA to request an investigation into the agency’s ability to operate with a single board member. The...more

Orrick, Herrington & Sutcliffe LLP

Regulators withdraw crypto guidance, plan further clarity for banks

On April 24, the FDIC and the Fed announced they have retracted two joint statements concerning banking organizations’ activities related to crypto-assets. According to the agencies, this move aims to clarify that banking...more

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