News & Analysis as of

Risk Management Office of the Comptroller of the Currency Climate Change

Mayer Brown

OCC Withdraws Climate Risk Management Principles

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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

Orrick, Herrington & Sutcliffe LLP

OCC withdraws climate risk guidelines for large banks

On March 31, the OCC announced that it had withdrawn from participating in the interagency principles for managing climate-related financial risks for large financial institutions....more

Jones Day

OCC Ends Climate Risk Guidance for Large Banks

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In a recent shift, the Office of the Comptroller of the Currency (OCC) has officially ended its climate risk guidance for large U.S. banks. The 2021 guidance called on major banks to incorporate climate-related risks into...more

Orrick, Herrington & Sutcliffe LLP

OCC discusses key risks in federal banking system

The OCC released the “OCC Semiannual Risk Perspective for Fall 2024,” which analyzes key risks facing the federal banking system as of mid-2024. Overall, “[t]he OCC reported that the strength of the federal banking system...more

Cadwalader, Wickersham & Taft LLP

Business As Usual, October 2024 - OCC Releases 2025 Bank Supervision Operating Plan

The Office of the Comptroller of the Currency’s Committee on Bank Supervision sets the agency’s supervision objectives and priorities. On October 1, the Committee released the OCC’s Bank Supervision Operating Plan (the...more

Spilman Thomas & Battle, PLLC

Promissory Notes - Banking & Finance Insights: V 4, Issue 1, January 2024

OCC Issues Guidance on ‘Buy Now, Pay Later’ Lending - “The guidance notes that banks should maintain underwriting, repayment terms, pricing, and safeguards that minimize adverse customer outcomes and should ensure that...more

Jones Day

Final Climate Risk Guidance Ensures Supervisory Focus from Banking Agencies in 2024

Jones Day on

The Situation: In October 2023, the Office of the Comptroller of the Currency ("OCC"), Federal Reserve System, and Federal Deposit Insurance Corporation ("FDIC," and the three agencies collectively, "Agencies") finalized...more

ArentFox Schiff

New Federal Climate Change Guidance for Large Banks Outlines Risk Management Framework

ArentFox Schiff on

On October 24, US banking regulators, the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, and Federal Deposit Insurance Corporation (the “agencies”), issued long-awaited guidance...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

Holland & Knight LLP on

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

Snell & Wilmer

Climate-Related Financial Risk Management Final Interagency Guidance Rules Issued – Now What’s Next?

Snell & Wilmer on

On October 24, 2023, the Federal Reserve (Fed), Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller of the Currency (OCC) issued the joint agency climate-related financial risk management guidance for...more

Orrick, Herrington & Sutcliffe LLP

Regulators release final principles for climate-related financial risk management

On October 25, the Fed, OCC, and FDIC issued final interagency guidance titled Principles for Climate-Related Financial Risk Management for Large Financial Institutions. The principles are intended to help the largest...more

Goodwin

Federal Reserve Invites Public Comment on Proposed Principles for Large Banking Organizations to Manage Climate-Related Financial...

Goodwin on

Regulatory Developments - Federal Reserve Invites Public Comment on Proposed Principles for Large Banking Organizations to Manage Climate-Related Financial Risks - On December 2, the Federal Reserve announced that it...more

Goodwin

OCC Seeks Feedback on Principles for Climate-Related Financial Risk Management

Goodwin on

In this Issue. The Office of the Comptroller of the Currency (OCC) is seeking feedback on principles for climate-related financial risk management for large banks; the Department of Justice’s Antitrust Division is seeking...more

Holland & Knight LLP

Is the Sky Really Falling? Acting Comptroller Proposes Key Questions for Banks on Climate Change

Holland & Knight LLP on

Canadian singer-songwriter Joni Mitchell lamented the toil of deforestation in 1970: "They took all the trees, put 'em in a tree museum/And they charged the people a dollar and a half just to see 'em." More than 50 years...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

Goodwin

SEC Adopts Broad Exempt Offering Reforms

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In the News. The Securities and Exchange Commission (SEC) adopted broad exempt offering reforms; the Department of Labor (DOL) finalized a rule, with significant revisions from the original proposal, on ESG investments; the...more

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