News & Analysis as of

Regulatory Reform Financial Institutions Regulatory Agencies

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

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

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

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

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

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

A&O Shearman

PRA announces withdrawal of the modification by consent for third country covered bonds in LCR

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The UK Prudential Regulation Authority (PRA) has announced it is withdrawing the modification by consent (MbC) for third country covered bonds in the Liquidity Coverage Ratio (LCR) part of the PRA Rulebook, which it had...more

Jones Day

Federal Reserve Withdraws Crypto-Related Guidance Including Notification Requirements for Banking Organizations

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The Federal Reserve Board ("Board") softened its stance on regulation of crypto activity by banking organizations by rescinding supervisory letters that created hurdles for crypto-asset activities and by joining the Office of...more

Sheppard Mullin Richter & Hampton LLP

Federal Regulators Signal Reversal on 2023 CRA Modernization Rule

On March 28, the Federal Reserve, FDIC, and OCC jointly announced plans to rescind 2023 revisions to the Community Reinvestment Act (CRA) regulations. The agencies stated they would return to the previous regulatory framework...more

Mayer Brown

Credibly Challenged Podcast: Interview With Mark Quandahl, Former Director of the Nebraska Department of Banking and Finance

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Joe Castelluccio and Matt Bisanz interview Mark Quandahl, the former Director of the Nebraska Department of Banking and Finance. They discuss his role in the implementation of the Nebraska Financial Innovation Act, including...more

Ballard Spahr LLP

House Subcommittee Chairman pushes legislation to convert CFPB into a commission, make it subject to appropriations

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House Financial Institutions Subcommittee Chairman Rep. Andy Barr, R-Ky., said last week that his subcommittee will place a high priority on changing the CFPB’s structure and funding....more

Ballard Spahr LLP

Banking Committee sends nomination of Jonathan McKernan as CFPB Director to full Senate

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The Senate Banking Committee on March 6 approved the nomination of Jonathan McKernan to be Director of the Consumer Financial Protection Bureau. ...more

Troutman Pepper Locke

Yet Another Leadership Change at the CFPB: Jonathan McKernan Nominated as Director

Troutman Pepper Locke on

On February 11, President Donald Trump nominated Jonathan McKernan to be the new Director of the Consumer Financial Protection Bureau (CFPB or Bureau). If confirmed by the Senate, McKernan will replace Acting CFPB Director...more

Stinson - Corporate & Securities Law Blog

CFTC Initiates Project KISS

In remarks at a conference, CFTC Acting Chairman J. Christopher Giancarlo announced the CFTC’s intent to comply with an Executive Order which requires each agency to designate a Regulatory Reform Officer and establish a...more

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