News & Analysis as of

Suspicious Activity Reports (SARs) Office of the Comptroller of the Currency

Sheppard Mullin Richter & Hampton LLP

OCC Issues Bulletins on Customer Financial Record Protections and Politicized Debanking

On September 8, the OCC issued two bulletins addressing banks’ obligations under the Right to Financial Privacy Act and clarifying how the agency will evaluate “politicized or unlawful debanking” in licensing and Community...more

Orrick, Herrington & Sutcliffe LLP

FinCEN issues guidance on cross-border information sharing for financial institutions

On September 5, FinCEN, in consultation with the FDIC, NCUA and the OCC, issued guidance to encourage the voluntarily cross-border sharing of information among financial institutions. ...more

Orrick, Herrington & Sutcliffe LLP

OCC announces actions to address politicized debanking practices

On September 8, the OCC announced new actions that aim to eliminate “politicized or unlawful debanking” in the federal banking system, consistent with Executive Order 14331: “Guaranteeing Fair Banking For All Americans”...more

Cooley LLP

Fed Signals Fraud a Top Priority in Special Compliance Outlook Issue

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The Federal Reserve (Fed) has devoted its entire Second Issue 2025 of Consumer Compliance Outlook (Outlook) to fraud – a rare, single-topic focus that underscores regulators’ and industry’s heightened concern for addressing...more

Troutman Pepper Locke

OCC to Assess Banks’ “Debanking” Practices as Part of Licensing and CRA Reviews

Troutman Pepper Locke on

On September 8, the Office of the Comptroller of the Currency (OCC) took significant action to “depoliticize” the federal banking system by issuing two bulletins to banks that further the goals of Executive Order 14331...more

Troutman Pepper Locke

Federal Banking Agencies Issue RFI on Payments and Check Fraud Mitigation Strategies

Troutman Pepper Locke on

On June 16, the Federal Deposit Insurance Corporation (FDIC), the Federal Reserve Board, and the Office of the Comptroller of the Currency (OCC) issued a joint request for public comment on potential ways to address payments...more

Troutman Pepper Locke

Strengthening Compliance: Lessons From the OCC's Consent Order With Patriot Bank — Payments Pros – The Payments Law Podcast

Troutman Pepper Locke on

In this episode of Payments Pros, host Carlin McCrory discusses a recent consent order between Patriot Bank and the Office of the Comptroller of the Currency (OCC) following a $27 million loss. The order addresses unsafe...more

Bradley Arant Boult Cummings LLP

Community Banks and BSA/AML Compliance: The OCC’s Consent Order with Clear Fork Bank Proves Regulators Aren’t Only Focused on...

On October 10, 2024, the financial services community was stunned by the $3.1 billion settlement between the federal government and TD Bank over Bank Secrecy Act (BSA) and anti-money laundering (AML) violations. TD Bank’s...more

Troutman Pepper Locke

Federal and State Financial Agencies Issue Guidance on Elder Financial Exploitation

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Earlier this week, the Board of Governors of the Federal Reserve System (FRB), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Financial Crimes Enforcement Network (FinCEN), National...more

Thomas Fox - Compliance Evangelist

TD Bank: Part 4- Watergate, Actual Knowledge and Conscious Indifference

Mike Volkov often told the story of watching the Watergate Hearings as a teenager and being a seminal influence on his later professional life in the legal profession and government service. It was my first exposure to...more

Lowenstein Sandler LLP

TD Bank to Pay Historic $3 Billion Over AML Compliance Violations

Lowenstein Sandler LLP on

On October 10, 2024, multiple U.S. federal and state agencies cumulatively fined a number of US based Toronto Dominion Bank subsidiaries (collectively, TD Bank or the Bank) more than $3 billion after finding that TD Bank...more

Troutman Pepper Locke

Federal Banking Agencies Reiterate Guidance on Managing Risks Posed By Fintech Partnerships and Other Third Party Relationships

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Last week, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies) issued a joint statement highlighting...more

WilmerHale

FinCEN’s Proposed AML/CFT Program Rule Potentially Heralds a Change in Approach

WilmerHale on

On June 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network announced long-anticipated proposed rules on anti-money laundering and countering the financing of terrorism program effectiveness;...more

Nutter McClennen & Fish LLP

Nutter Bank Report: December 2023

A recent OCC report identified key issues facing the federal banking system, including increasing credit risk due to higher interest rates, increasing risk in commercial real estate lending, prolonged inflation, declining...more

Ballard Spahr LLP

OCC Risk Perspective Report Focuses on Third-Party Relationships with Fintechs

Ballard Spahr LLP on

In its Fall 2023 Semiannual Risk Perspective, published on December 7, the Office of the Comptroller of the Currency (“OCC”) reported on key issues facing the federal banking system. In evaluating the overall soundness of...more

Troutman Pepper Locke

OCC’s Semiannual Report Highlights Emerging Risk of AI in Banking

Troutman Pepper Locke on

On December 7, the Office of the Comptroller of the Currency (OCC) published the fall edition of its Semiannual Risk Perspective, which discusses key issues facing banks. From the OCC’s perspective, the overall strength of...more

Goodwin

CFPB Launches New Initiative Focused on Rural Communities

Goodwin on

In This Issue. The Consumer Financial Protection Bureau (CFPB) announced a new initiative focused on financial issues faced by rural communities and also updated its examination procedures to cover unfair discrimination; the...more

Miller Nash LLP

I Just Wanna Know—Federal Bank Regulators to Require Notice of Major Cyber Security Events

Miller Nash LLP on

Hardly a day goes by without news of a new cybercrime hobbling a major business.1 The grand scope of the SolarWinds hack, which went undetected for many months, underscored that even the most sophisticated technology...more

Goodwin

Federal Agencies Issue Joint Statement on Management of LIBOR Transition

Goodwin on

In This Issue. Federal agencies issued a joint statement regarding an orderly transition away from the London Interbank Offered Rate (LIBOR); the Office of the Comptroller of the Currency (OCC) issued an updated...more

Goodwin

Biden Administration Issues Regulatory Freeze On New Agency Rules

Goodwin on

In this Issue. In one of its first acts after being installed on January 20, the Biden Administration issued a regulatory freeze on new agency rules that have been adopted but are not yet effective; in one of its final acts...more

Nutter McClennen & Fish LLP

Nutter Bank Report: January 2021

Updated Annual Meeting Guidance for Mutual Banks and Mutual Holding Companies - The Massachusetts Division of Banks has issued new guidance to mutual banks and mutual holding companies that have not yet held their 2020...more

Perkins Coie

Blockchain Week in Review - January 2021

Perkins Coie on

Federal Regulation Actions Frozen Pending Review from New Administration - On January 20, 2021, newly inaugurated President Joe Biden issued a memorandum to the Heads of Executive Departments and Agencies asking current...more

Perkins Coie

Fintech Week in Review - January 2021 #3

Perkins Coie on

Federal Regulation Actions Frozen Pending Review from New Administration - On January 20, 2021, newly inaugurated President Joe Biden issued a memorandum to the Heads of Executive Departments and Agencies asking current...more

Ballard Spahr LLP

The OCC Embraces Technology, Proposes Exemption to SAR Requirements and Announces Acceptance of Distributed Ledgers and...

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The Comptroller of the Currency (the “OCC”) has been busy, and focused on technology. We discuss two recent developments: proposed regulations that would allow the OCC to grant exemptions relating to Suspicious Acivity...more

Goodwin

FDIC Finalizes Brokered Deposits and ILC Rules Ahead of the Holidays

Goodwin on

In this Issue. The Federal Deposit Insurance Corporation (FDIC) was busy this week, finalizing rules that modernize brokered deposits regulations, establish new standards for parent companies of industrial loan companies and...more

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