News & Analysis as of

Regulatory Agencies Office of the Comptroller of the Currency Banking Sector

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

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

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

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

BakerHostetler on

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

Amundsen Davis LLC

Banking Regulators Signal Change in Cryptocurrency Approach

Amundsen Davis LLC on

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

Husch Blackwell LLP

OCC Aims to Streamline Bank Merger Reviews

Husch Blackwell LLP on

On May 8, 2025, the Office of the Comptroller of the Currency (OCC) announced its adoption of an interim final rule (IFR) that amends its 2024 final rule related to its regulations for business combinations involving national...more

Orrick, Herrington & Sutcliffe LLP

OCC releases April 2025 enforcement actions

On April 17, the OCC announced enforcement actions against three institution-affiliated parties, alleging in the first instance fund misappropriation, in the second Paycheck Protection Program fraud, and in the last...more

Cadwalader, Wickersham & Taft LLP

New Regulatory Priorities Spring Into Focus, April 2025 - Fed, FDIC and OCC Move to Rescind 2023 CRA Rule

The Federal Deposit Insurance Corporation (“FDIC"), Federal Reserve Board (“FRB”), and the Office of the Comptroller of the Currency (“OCC”) (collectively, “the Agencies”) announced, that they intend to issue a proposal to...more

Orrick, Herrington & Sutcliffe LLP

Bank regulators to rescind the CRA final rule

On March 28, the FDIC, the Fed, and the OCC announced their intention to issue a proposal to rescind the CRA final rule that was issued in October 2023 (covered by InfoBytes here). According to the prudential regulators, this...more

Troutman Pepper Locke

Federal Banking Agencies Announce Intent to Rescind 2023 Community Reinvestment Act Final Rule

Troutman Pepper Locke on

On March 28, the Federal Reserve Board, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (together, the federal banking agencies) announced their intent to rescind the...more

Troutman Pepper Locke

Treasury Secretary Bessent to Appoint Rodney E. Hood as First Deputy Comptroller of the OCC

Troutman Pepper Locke on

On February 7, Secretary of the Treasury Scott Bessent announced that he will appoint Rodney E. Hood as a Deputy Comptroller and designate him as the First Deputy Comptroller of the Office of the Comptroller of the Currency...more

Cadwalader, Wickersham & Taft LLP

Banking Agencies Finalize Interagency Policy Statement on CRE Loan Workouts

On June 30, the Federal Reserve Board (“FRB”), Federal Deposit Insurance Corporation (“FDIC”), Office of the Comptroller of the Currency (“OCC”) and the National Credit Union Administration (“NCUA”) finalized their Policy...more

Goodwin

Agencies Publish Notice and Request for Comment on Proposed Interagency Guidance on Third-Party Relationships

Goodwin on

In This Issue. The federal bank regulatory agencies requested public comment on proposed guidance designed to help banking organizations manage risks associated with third-party relationships; the Office of the Comptroller of...more

Foley Hoag LLP

Regulatory Agencies Propose to Modify Volcker Rule

Foley Hoag LLP on

On January 30, 2020, five federal regulatory agencies, the Commodity Futures Trading Commission, the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board, the Office of the Comptroller of the Currency,...more

Eversheds Sutherland (US) LLP

Federal agencies clarify SAR filing requirements for financial services provided to hemp-related businesses

On December 3, 2019, four federal agencies, in consultation with state banking regulators, clarified the legal status of hemp growth and production under the Bank Secrecy Act (BSA) for banks providing financial services to...more

Dorsey & Whitney LLP

Banking Services for Hemp Growers – FinCEN Makes a Statement

Dorsey & Whitney LLP on

On December 3, 2019, FinCEN, along with the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency, in consultation with the Conference of...more

Bradley Arant Boult Cummings LLP

Is the Bank Open? Federal Agencies Clarify Regulatory Requirements for Banking Hemp

On December 3, several federal agencies issued guidance (Guidance) that, by its terms, “provide[s] clarity” regarding “the regulatory requirements under the Bank Secrecy Act (BSA) for banks providing services to hemp-related...more

A&O Shearman

US State Regulators Sue Office of the Comptroller of the Currency Over FinTech Charter

A&O Shearman on

The Conference of State Bank Supervisors has sued the U.S. Office of the Comptroller of the Currency to prevent it from granting charters for special purpose national banks to non-depository FinTech companies. The CSBS is the...more

WilmerHale

Banking Regulators' Examination Authority Does Not Override Attorney-Client Privilege

WilmerHale on

Notwithstanding the venerable status of the attorney client privilege and the important purposes it serves, the federal banking regulators and the Consumer Financial Protection Bureau have taken the position that they have...more

Nossaman LLP

Major Security Breach Reported to Congress By Federal Bank Regulator

Nossaman LLP on

Recently, the Office of the Comptroller of the Currency (OCC) informed Congress that it had suffered a major information security incident. The agency reported that, in November 2015, a former employee downloaded over...more

Troutman Pepper

Observation 3.0: Frequently Asked Questions and Answers on the Volcker Rule and the Implications for Foreign Banks Investing in...

Troutman Pepper on

1. Question: What is the Volcker Rule, and when does it take effect? Answer: The Volcker Rule was enacted into law as section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank...more

K&L Gates LLP

Federal Financial Regulatory Agencies Release Final Diversity Standards

K&L Gates LLP on

After lengthy consideration, six federal financial regulatory agencies—the Consumer Financial Protection Bureau, Office of the Comptroller of the Currency, Federal Reserve Board of Governors, Federal Deposit Insurance...more

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