News & Analysis as of

Risk Management Office of the Comptroller of the Currency Regulatory Agencies

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

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

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

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

Orrick, Herrington & Sutcliffe LLP

Financial services industry trade groups pen letter to Treasury Secretary Bessent on cybersecurity risks

On June 9, multiple financial services trade associations sent a letter to Treasury Secretary Scott Bessent expressing concerns about cybersecurity risk management practices at federal regulatory agencies following the OCC’s...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

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

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