News & Analysis as of

Supervision Banking Sector Financial Institutions

Nutter McClennen & Fish LLP

Nutter Bank Report: June 2025

The Federal Reserve has announced that the agency will no longer assess reputational risk when examining banks’ risk management processes. According to the June 23 announcement, the Federal Reserve has already begun reviewing...more

Goodwin

Consequences of Forming or Acquiring a Depository Institution

Goodwin on

This second installment in a series of insights on bank charter considerations describes the consequences of operating through an insured depository institution charter, including capital requirements, supervision and...more

A&O Shearman

BCBS provides an update on upcoming workstreams

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The Basel Committee on Banking Supervision (BCBS) has published a press release providing an update on its workstreams. The BCBS states that it will publish by mid-2025 an update on the outcome of its work to prepare a suite...more

WilmerHale

Interagency Issuances on Bank-Fintech Partnerships Highlights Risks, Opportunities, Importance of Industry Participant Engagement

WilmerHale on

The recent bank regulatory Joint Statement and request for information (RFI) on third-party deposit relationships and bank-fintech partnerships emphasize afresh regulators’ long-standing concern with financial institutions’...more

Venable LLP

CFPB Updates the Supervisory Appeals Process

Venable LLP on

The Consumer Financial Protection Bureau (CFPB) released a procedural rule updating its supervisory process for institutions seeking to appeal a compliance rating or an adverse finding. Although the appeals process remains...more

WilmerHale

New York Department of Financial Services Proposes Heightened Standards for Character and Fitness of Executives

WilmerHale on

On May 9, New York State Department of Financial Services (DFS or the Department) Superintendent Adrienne A. Harris issued proposed guidance to clarify the DFS’s updated expectations regarding the review and assessment of the...more

Bradley Arant Boult Cummings LLP

Regulatory Review, Reformatted

As 2021 runs in search of what’s new, we realize that the pandemic disruption has continued through 2021. The NMLS Ombudsman Meeting was held virtually and the upcoming American Association of Residential Mortgage Regulators...more

A&O Shearman

Basel Committee on Banking Supervision Publishes Statement on Proportionate Implementation of Basel Framework

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The Basel Committee on Banking Supervision has published a joint statement with the Basel Consultative Group on the proportionality of the implementation of the Basel Framework by the banks and jurisdictions to which it...more

Eversheds Sutherland (US) LLP

FinCEN demystifies risk-focused Bank Secrecy Act/anti-money laundering supervision

Last week, the Financial Crimes Enforcement Network (FinCEN) and its regulatory partners issued a joint statement in an effort to increase transparency around risk-focused Bank Secrecy Act/anti-money laundering supervision....more

Miles & Stockbridge P.C.

“Guidance” is Not the Same as Law: The Role of Supervisory Guidance for Regulated Financial Institutions

“Supervisory guidance does not have the force and effect of law, and the agencies do not take enforcement actions based on supervisory guidance.” On September 11, 2018, the Bureau of the Consumer Financial Protection,...more

A&O Shearman

US Federal Reserve Vice Chairman Randal Quarles Discusses Streamlining the Supervision and Regulation of Large Financial...

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U.S. Board of Governors of the Federal Reserve System Vice Chairman for Supervision, Randal Quarles, discussed the tailoring of supervision and regulation for large financial institutions. Vice Chairman Quarles noted that...more

Alston & Bird

New York City’s RBA Falls to Preemption Challenge

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New York City banks are breathing a sigh of relief after a federal judge ruled that they would not have to provide detailed servicing disclosures under a preempted city law. The law, a gloss on top of the federal Community...more

Orrick - Finance 20/20

Federal Reserve Board Releases Additional Information on the LISCC Supervisory Program

Orrick - Finance 20/20 on

On April 17, the Federal Reserve Board published a Supervision and Regulation Letter containing additional information on the operating structure of the Large Institution Supervision Coordinating Committee (LISCC) supervisory...more

Orrick - Finance 20/20

Comptroller of the Currency Discusses Tailoring Supervisory Expectations to the Size and Complexity of Regulated Institutions

Orrick - Finance 20/20 on

On March 19, the Comptroller of the Currency, Thomas Curry, discussed the Office of the Comptroller of the Currency’s approach to tailoring regulatory and supervisory expectations to the size and complexity of supervised...more

Sheppard Mullin Richter & Hampton LLP

CFPB Issues Compliance Bulletin On Confidentiality of Supervisory Information

On January 27, 2015, the Consumer Financial Protection Bureau (“CFPB”) issued a compliance bulletin reminding supervised financial institutions (including large depository institutions, credit unions and their affiliates,...more

Ballard Spahr LLP

Supervisory or Enforcement Action? Deputy Director Explains How the CFPB Decides

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In his prepared remarks for an appearance last month at the Exchequer Club, Consumer Financial Protection Bureau Deputy Director Steven Antonakes discussed the CFPB’s risk-based approach to supervision. (The Exchequer Club’s...more

Ballard Spahr LLP

CFPB issues compliance bulletin on treatment of confidential supervisory information

Ballard Spahr LLP on

In a new compliance bulletin (2015-01), the CFPB reminds supervised financial institutions, including nonbanks, of their obligations regarding the disclosure of confidential supervisory information (CSI)....more

Troutman Pepper

Virtual Currency, Real Risks

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CSBS publishes Draft Model Regulatory Framework to promote consistent state regulation of virtual currency activities and protect consumers in the event of a breach. In March 2014, “Mt. Gox,” one of the largest and best-known...more

Morrison & Foerster LLP

The CFPB 2015 Forecast: Continued Cloudiness, Thunderstorms Likely

This will be a busy year at the Consumer Financial Protection Bureau (CFPB), and that certainly means it will be a busy year for financial institutions as well. In addition to exercising its supervisory and enforcement...more

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