News & Analysis as of

Regulatory Oversight Office of the Comptroller of the Currency Risk Management

Orrick, Herrington & Sutcliffe LLP

OCC releases June 2025 enforcement actions

On June 18, the OCC announced enforcement actions against national banks, federal savings associations, and individuals currently or previously affiliated with supervised institutions. The OCC entered into three agreements...more

Sheppard Mullin Richter & Hampton LLP

OCC Enters Consent Orders Against New York-based Bank

On May 14, the OCC entered into a formal agreement with a New York-based bank after determining that the institution is in “troubled condition.” In its findings, the OCC cited alleged unsafe or unsound practices tied to the...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

Troutman Pepper Locke

Federal Banking Agencies Issue RFI on Payments and Check Fraud Mitigation Strategies

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On June 16, the Federal Deposit Insurance Corporation (FDIC), the Federal Reserve Board, and the Office of the Comptroller of the Currency (OCC) issued a joint request for public comment on potential ways to address payments...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

Fenwick & West LLP

Bank-Fintech Partnerships Under Scrutiny: What Fintechs Need to Know About AML Expectations

Fenwick & West LLP on

Bank-fintech partnerships have transformed the financial services landscape, creating new opportunities and challenges for traditional banking institutions and innovative technology companies alike. In a typical arrangement,...more

Orrick, Herrington & Sutcliffe LLP

GAO Report Reveals How Financial Institutions (And Their Regulators) Are Using AI

Curious about how financial institutions, their service providers, and their federal regulators are using and overseeing machine learning and other AI tools? A new GAO report published on May 19th (the “Report”) provides a...more

Orrick, Herrington & Sutcliffe LLP

OCC releases May 2025 enforcement actions

On May 15, the OCC announced enforcement actions against two banks and three institution-affiliated parties. The OCC issued cease and desist orders to banks in Miami, as well as Beverly Hills, California, respectively, for...more

Patomak Global Partners

Fed Withdrawal of Guidance Marks Milestone for Banks’ Future Crypto Activity

The federal banking agencies have withdrawn previously issued guidance related to banks’ crypto activities, marking a shift in regulatory posture toward digital asset engagement. On April 25, the Federal Reserve Board...more

Sheppard Mullin Richter & Hampton LLP

OCC Confirms Banks Authority to Offer Crypto Custody and Execution Services

On May 7, the OCC issued Interpretive Letter 1184, reaffirming that national banks and federal savings associations may provide cryptocurrency custody and execution services, including through sub-custodians. The OCC...more

Orrick, Herrington & Sutcliffe LLP

OCC requests information on banks’ digitalization efforts

On May 5, the OCC released a request for information (RFI) seeking public comment on community banks’ efforts towards digitalization. The OCC stated this RFI will enhance its supervisory activities. The OCC aims to understand...more

McGuireWoods LLP

Banks May Provide Cryptocurrency Transaction and Custody Services, but OCC Has Yet to Provide Clear Compliance Requirements

McGuireWoods LLP on

On May 7, 2025, the Office of the Comptroller of the Currency (“OCC”) issued a follow up to its July 2020 Interpretative Letter 1170, which allowed national banks to provide cryptocurrency custody services to their customers....more

Sheppard Mullin Richter & Hampton LLP

OCC’s Hood Emphasized AI Oversight and Inclusion in Financial Services

On April 29, Acting Comptroller of the Currency Rodney Hood delivered pre-recorded remarks at the National Fair Housing Alliance’s Responsible AI Symposium.  In his speech, Hood reiterated the OCC’s commitment to deploying AI...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

Stinson LLP

CFPB and OCC Signal Strategic Shifts in Supervision and Enforcement

Stinson LLP on

In April 2025, both the Consumer Financial Protection Bureau (CFPB) and the Office of the Comptroller of the Currency (OCC) announced significant changes to their supervisory and enforcement approaches, signaling a shift in...more

Mayer Brown

OCC Withdraws Climate Risk Management Principles

Mayer Brown on

On March 31, 2025, the Office of the Comptroller of the Currency withdrew its participation in the interagency principles for climate-related financial risk management for large financial institutions (the “Climate...more

Troutman Pepper Locke

OCC Ceases Examinations for Reputation Risk Following Legislative Push

Troutman Pepper Locke on

On March 20, the Office of the Comptroller of the Currency (OCC) announced that it will no longer examine its regulated institutions for reputation risk. According to the OCC’s “Categories of Risk,” reputation risk is the...more

Cadwalader, Wickersham & Taft LLP

Summer Regulatory Round-Up | July 2024

The banking regulators have not yet gone out on vacation, as demonstrated by this grab-bag of announcements, speeches, rules and guidance: Acting Comptroller of the Office of the Comptroller of the Currency (OCC),...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

Ballard Spahr LLP

Acting Comptroller Hsu Highlights Latest Efforts of OCC in Elevating Financial Fairness

Ballard Spahr LLP on

On April 4, acting Comptroller of the Currency Michael J. Hsu provided his remarks for the second year in a row at the Just Economy Conference hosted by the National Community Reinvestment Coalition. He focused his remarks on...more

Sheppard Mullin Richter & Hampton LLP

Federal Agencies Request Comments on Risk Management Guidance for Third-Party Relationships

On July 13, the Federal Reserve, FDIC, and OCC proposed risk management guidance to help banking organizations manage risks related to third-party relationships, including relationships with vendors, FinTech companies,...more

Mitratech Holdings, Inc

OCC Steps Up Scrutiny of EUCs at Financial Institutions

Mitratech Holdings, Inc on

EUCs – End User Computing applications – have hit the headlines again, after the US Office of the Comptroller of the Currency (OCC) levied a $400 million fine on an American-based bank. It found issues in the institution’s...more

Troutman Pepper Locke

Call to Innovate: Is Your Bank Ready?

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In October 2018 the FDIC became the latest federal financial regulator to announce plans to create an Office of Innovation, following on the heels of the OCC and the CFPB. Originally published in Delaware Banker - Winter...more

Troutman Pepper Locke

New OCC Bulletin on Third-Party Oversight Highlights Fintech Relationships

Troutman Pepper Locke on

On June 7, the Office of the Comptroller of the Currency (OCC) issued OCC Bulletin 2017-21 (Frequently Asked Questions to Supplement Bulletin 2013-29; Third-Party Relationships: Risk Management Guidance). This is the OCC’s...more

Goodwin

OCC Hosts Forum on Responsible Innovation

Goodwin on

On June 23, 2016, the Office of the Comptroller of the Currency (OCC) hosted a daylong forum, “Supporting Responsible Innovation in the Federal Banking System.” The purpose of the forum was to encourage a dialogue among...more

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