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
Following the Freedom of Information Act (FOIA) litigation brought against the Federal Deposit Insurance Corporation (FDIC) in 2024, on February 5, 2025, the FDIC released hundreds of pages of documents related to its...more
The OCC has removed “reputational risk” from its handbooks and guidance and the FDIC is moving to do the same. ...more
On April 15, the FDIC announced updated guidance on sending official correspondence related to supervisory matters. The FDIC’s guidance made permanent those temporary, previous measures for electronically sending and...more
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
Earlier this month, the Federal Reserve Board (FRB) released two supervision and regulation letters regarding the agency’s program to supervise “novel” banking activities....more
On Monday, Federal Deposit Insurance Corporation (“FDIC”) Chair Martin Gruenberg gave remarks to the Brookings Institution on “The Resolution of Large Regional Banks.” Chair Gruenberg did not say “I told you so” in his...more
The Federal Deposit Insurance Corporation (“FDIC”) on August 18, 2022 issued updated Supervisory Guidance on banks assessing multiple re-presentment fees against customers’ accounts. This follows the March 2022 FDIC Consumer...more
On April 9, 2021, the federal banking regulatory agencies (the Federal Reserve, FDIC and OCC) together with FinCEN and the National Credit Union Administration issued a joint statement addressing how risk management...more