News & Analysis as of

Supervisory Guidance Financial Institutions

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

Orrick, Herrington & Sutcliffe LLP

FDIC updates electronic communication procedures for supervisory correspondence

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

Troutman Pepper Locke

CFPB Announces 2025 Supervision and Enforcement Priorities

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This week, the Consumer Financial Protection Bureau (CFPB or Bureau) released a memo to staff outlining its new supervision and enforcement priorities for 2025....more

Ballard Spahr LLP

CFPB rescinds enforcement, supervisory priority documents, outlines new priorities for 2025

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The CFPB is rescinding its existing enforcement and supervision priority documents, according to a memo sent to bureau staff by CFPB Chief Legal Officer Mark Paoletta....more

Troutman Pepper Locke

NCUA Releases its 2025 Supervisory Priorities

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On January 7, the National Credit Union Administration (NCUA) released its supervisory priorities for 2025, outlining the key areas of focus for federally insured credit unions. This guidance is crucial for credit unions as...more

Ballard Spahr LLP

CFPB issues final rule to give bureau supervisory power over digital consumer payment applications

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The CFPB has issued a final rule to supervise large nonbank financial services providers that offer general-use digital consumer payment applications such as digital wallets and peer-to-peer payment apps....more

Ballard Spahr LLP

CFPB revises supervisory appeals process (UPDATED)

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The CFPB has revised its internal supervisory appeals process for institutions seeking to appeal a compliance rating or an adverse material finding.  The revisions became effective immediately upon publication in the Federal...more

Ballard Spahr LLP

Credit unions should expect increased supervision from NCUA on overdraft/NSF fees, vendor risk, and fair lending

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On February 6, 2024, National Credit Union Administration (NCUA) Chairman Todd M. Harper spoke at a Brookings Institution event to outline his regulatory agenda and supervisory priorities for 2024. His prepared remarks...more

Troutman Pepper Locke

NCUA Announces Supervisory Priorities for 2024

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On January 23, the Chairman of the National Credit Union Administration (NCUA) released a letter outlining its supervisory priorities for the new year. While the organization acknowledged that the credit union system had...more

Cadwalader, Wickersham & Taft LLP

The UK’s Banking Regulator Sets Out 2024 Priorities

Rebecca Jackson, Executive Director, Authorisations, Regulatory Technology, and International Supervision at the Prudential Regulation Authority ("PRA") has written to international banks on the PRA’s thematic supervision...more

Jones Day

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

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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

Troutman Pepper Locke

FSOC Votes Unanimously to Finalize Process for Designating Nonbanks for Federal Reserve Supervision

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On November 3, the Financial Stability Oversight Council (FSOC) voted unanimously to finalize the procedures for designating a nonbank financial company for Federal Reserve supervision. FSOC’s Interpretive Guidance aims to...more

Stikeman Elliott LLP

OSFI Releases New Supervisory Framework for FRFIs and Pension Plans

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On October 4, 2023, the Office of the Superintendent of Financial Institutions (“OSFI”) released details of a new supervisory framework (“New Framework”) that will apply as of April 1, 2024 to federally-regulated financial...more

Ballard Spahr LLP

OCC issues bank supervision operating plan for fiscal year 2024

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The Office of the Comptroller of the Currency’s (OCC) Committee on Bank Supervision (CBS) recently issued its annual Bank Supervision Operating Plan for FY 2024, which sets forth the OCC’s supervision priorities and...more

Ballard Spahr LLP

FDIC Moves to Dismiss Lawsuit Challenging NSF Fee Guidance

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The FDIC has filed motion to dismiss the lawsuit filed in July 2023 in a Minnesota federal district against the FDIC and its Chairman seeking to invalidate the FDIC’s supervisory guidance on charging multiple non-sufficient...more

Ballard Spahr LLP

Federal Reserve Board issues letters on program to supervise novel banking activities

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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

Cadwalader, Wickersham & Taft LLP

FDIC Chair Speaks on Resolution of Large Regional Banks

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

Cadwalader, Wickersham & Taft LLP

Basel Committee Issues Guidance on Core Principles for Effective Banking Supervision

In April 2022, the Basel Committee on Banking Supervision (the Basel Committee) began a review of “the core principles for effective banking supervision” (Core Principles or CP). Last month, the Basel Committee published...more

Cadwalader, Wickersham & Taft LLP

Federal Reserve Says Permission Required for State Banks to Be Involved in Stablecoin Issuance

The Federal Reserve issued a Supervision and Regulation letter earlier this week to all state member banks (“SMBs”) regarding their involvement in activities involving stablecoins, taking an even more reticent position than...more

Cadwalader, Wickersham & Taft LLP

Fed Establishes Novel Activities Supervision Program

Earlier this week, the Federal Reserve issued a Supervision and Regulation Letter regarding the “Creation of Novel Activities Supervision Program” (SR 23-7). The letter informs all banking organizations subject to supervision...more

Cadwalader, Wickersham & Taft LLP

Basel Committee Guidance on Core Principles for Effective Banking Supervision

In April 2022, the Basel Committee on Banking Supervision (the Basel Committee) began a review of “the core principles for effective banking supervision” (Core Principles or CP). Last month, the Basel Committee published a...more

Ballard Spahr LLP

Minnesota Bankers Association and Lake Central Bank sue FDIC over NSF fee guidance

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A complaint filed on July 20, 2023 in Minnesota federal court seeks declaratory and injunctive relief under the Administrative Procedures Act (APA) against defendants Federal Deposit Insurance Corporation (FDIC) and Chairman...more

Troutman Pepper Locke

OCC Senior Deputy Comptroller for Large Bank Supervision Provides Insight on Impact to Community Banks of the OCC’s Principles for...

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On July 18, Office of the Comptroller of the Currency (OCC) Senior Deputy Comptroller for Large Bank Supervision Greg Coleman testified on OCC supervision of climate-related financial risks before the U.S. House of...more

Mayer Brown Free Writings + Perspectives

Basel Committee Seeks Public Comments on Bank Supervision

On July 6, 2023, the Basel Committee on Banking Supervision (“Basel Committee”) released proposed revisions to its core principles for effective banking supervision (the “Revised Principles”). The Revised Principles are...more

Orrick, Herrington & Sutcliffe LLP

Fed says limits on banking activities will apply regardless of insurance status

On January 27, the Federal Reserve Board issued a policy statement providing guidelines on how the agency evaluates requests from supervised uninsured and insured banks seeking to engage in novel activities, such as those...more

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