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Risk Management New Guidance Financial Institutions

Amundsen Davis LLC

President Trump Takes Action to Ensure Fair Banking for All Americans

Amundsen Davis LLC on

On August 7, 2025, President Donald J. Trump signed an executive order titled “Guaranteeing Fair Banking for All Americans.” The order asserts that financial institutions have restricted the access of individuals and...more

Husch Blackwell LLP

New Exemption Order Creates More Flexibility and More Considerations with the Customer Identification Program Rule

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By an exemption order dated June 27, 2025, federal prudential regulators have given banks and credit unions some welcomed flexibility when collecting an individual’s or entity’s taxpayer identification number (TIN) during...more

Bressler, Amery & Ross, P.C.

NY Department of Financial Services Issues Guidance to its Regulated Industry As a Result of the Ongoing Global Conflict

The New York State Department of Financial Services (the “Department”) has issued guidance (“Guidance”) to all individuals and entities regulated by the Department (“Regulated Entities”) to underscore the importance of...more

A&O Shearman

CMORG AI Taskforce releases comprehensive AI Baseline Guidance

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The Cross Market Operational Resilience Group's (CMORG) AI Taskforce has released its AI Baseline Guidance Review (dated January 2025), accompanied by a press release. The CMORG AI Taskforce conducted a baseline review of...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

McGuireWoods LLP

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

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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

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

Sheppard Mullin Richter & Hampton LLP

FDIC Updates Crypto Guidance, Removes Pre-Approval Requirement for Banks

On March 28, the FDIC issued updated guidance clarifying the process for FDIC-supervised institutions to engage in crypto-related activities. The guidance rescinds and replaces prior instructions issued in 2022 and makes...more

Orrick, Herrington & Sutcliffe LLP

FDIC no longer requires notification of crypto-related activities

On March 28, the FDIC announced new guidance allowing FDIC-supervised institutions to engage in permissible crypto-related activities without prior approval. This update, outlined in FIL-7-2025, rescinded the previous...more

A&O Shearman

SRB consultation on operational guidance on resolvability testing for banks

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The Single Resolution Board (SRB) has opened a consultation on its operational guidance on resolvability testing for banks under the SRB's remit. It aims to ensure that European banks are regularly testing their capabilities...more

Husch Blackwell LLP

Acting CFTC Chairman Caroline D. Pham Releases Additional Enforcement Guidance

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On March 11, acting Commodity Futures Trading Commission (CFTC) Chairman Caroline D. Pham offered insight into the regulator’s February 25, 2025 advisory in a keynote addressed delivered at Boca, the annual International...more

Venable LLP

DOJ Revises Its Evaluation of Corporate Compliance Policy to Consider How Companies Address Risks Posed by AI

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The Department of Justice's Criminal Division is "using more tools than ever before to identify corporate misconduct and to encourage companies to be good corporate citizens," according to Nicole Argentieri, Principal Deputy...more

Nutter McClennen & Fish LLP

Nutter Bank Report: July 2024

The federal banking agencies have published joint guidance for banks about risks posed by fintech companies and other third parties to deliver bank deposit products and services. The joint guidance issued on July 30...more

Baker Donelson

[Webinar] New Privacy and Cybersecurity Regulations: What Financial Institutions Need to Know to Stay Compliant - June 13th, 10:00...

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The financial services industry has seen a litany of new data privacy and cybersecurity challenges through the first half of 2024. Financial institutions are facing unprecedented compliance hurdles resulting from the...more

Venable LLP

Crystal Clear: New Guide on Third-Party Risk Management for Community Banks - and Others

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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

Latham & Watkins LLP

Hong Kong Monetary Authority Issues Guidance for Banks on Crypto Custody and Sale of Tokenised Products

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Regulator sets out its expectations for banks looking to provide digital asset custody services, and sell and distribute tokenised products. On 20 February 2024, the Hong Kong Monetary Authority (HKMA) published two...more

Ballard Spahr LLP

New York DFS Issues Guidance on Climate Change Risks for Financial Institutions

Ballard Spahr LLP on

On December 21, 2023, the New York Department of Financial Services (“DFS”) published guidance (the Guidance) to assist regulated institutions in assessing and managing their climate-related financial and operational risks....more

Latham & Watkins LLP

OCC Issues Policy Guidance on Venture Loans

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The OCC outlines safety and soundness principles and appropriate risk management processes for its regulated institutions that engage in venture lending. On November 1, 2023, the Office of the Comptroller of the Currency...more

Morrison & Foerster LLP

OCC Issues Guidance on Venture Lending

Morrison & Foerster LLP on

On November 1, 2023, the Office of the Comptroller of the Currency (OCC) issued detailed guidance (the Bulletin) to national banks and federal savings associations addressing risk management standards and safe and sound...more

Venable LLP

Tinker, Tailor, Banker, FSOC Designation: New Guidance for Bank-like Regulation and Supervision of Non-Banks

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Since the 2023 spring bank failures, the federal banking agencies have tinkered with significant bank regulations and guidance—ranging from capital, bail-in measures, and resolution planning to climate-risk stress testing,...more

Latham & Watkins LLP

OCC, FRB, and FDIC Finalize Joint Principles for Climate-Related Financial Risk Management

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Guidance for the largest US financial institutions is intended to promote climate risk management consistent with general safety and soundness practices. On October 30, 2023, the three US federal bank regulatory agencies...more

Holland & Knight LLP

Agency Guidelines Confirm That Climate-Related Financial Risk Is Real

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The U.S. Department of the Treasury's Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System (Board) and the Federal Deposit Insurance Corp. (FDIC) (collectively, the Agencies) on...more

Hudson Cook, LLP

Federal Bank Regulatory Agencies Issue Final Joint Guidance for Managing Third-Party Relationship Risks

Hudson Cook, LLP on

On June 6, 2023, the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, and the Office of the Comptroller of the Currency issued final joint guidance addressing bank management of...more

Goodwin

Bank Regulators Issue Guidance for Third-Party Risk Management

Goodwin on

On June 6, 2023, the Board of Governors of the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, Agencies)...more

Sheppard Mullin Richter & Hampton LLP

FDIC, FRB & OCC Issue Final Guidance on Risk Management for Third-Party Relationships

On June 6, the FDIC, FRB & OCC issued final interagency guidance intended to assist their respective supervised banking organizations in identifying and managing risks associated with third-party relationships and in...more

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