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10 Nov 2023, 9:02 am
On November 1, 2023, the Office of the Comptroller of the Currency (“OCC”) became the latest agency to join in the campaign by issuing its TCPA-related revised examination procedures (“Revised Procedures”). [read post]
8 Nov 2023, 9:05 pm
In contrast, CITs are set up by banks or trust companies, available to individuals only through employer-sponsored retirement plans, and regulated primarily by the Office of the Comptroller of the Currency (OCC) and, in some cases, by the Department of Labor (DOL). [read post]
29 Oct 2023, 9:01 pm
The preamble, referring to the post-mortem evaluations of the Signature Bank and Silicon Valley Bank (“SVB”) failures conducted by the FDIC and the Federal Reserve Board (the “FRB”), notes that poor governance and risk management practices were contributing factors leading to the failure of those banks.[2] The Proposed Guidelines are generally consistent with and draw from both the Office of the Comptroller of the Currency (the “OCC”)’s… [read post]
26 Oct 2023, 7:30 am
On October 24, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation issued a final rule amending their regulations implementing the Community Reinvestment Act. [read post]
25 Oct 2023, 9:01 pm
The Federal Reserve OIG issued a report on SVB’s failure. [read post]
16 Oct 2023, 9:01 pm
The proposal was issued over two dissents.1 Among the issues the dissents highlighted is that the proposal would seek to impose an enforceable federal overlay on state fiduciary duty standards, which would extend beyond the scope of the Office of the Comptroller of the Currency’s (OCC) governance guidelines2 and of the Federal Reserve Board’s (FRB) governance guidance.3 The proposal also would muddy the waters between board and management… [read post]
9 Oct 2023, 12:46 pm
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 objectives across CBS operating units. [read post]
28 Sep 2023, 9:22 am
And the CFPB’s funding statute is “not materially distinct from” those of other financial regulators such as the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, and the Federal Reserve Board itself, the CFPB asserts. [read post]
26 Sep 2023, 9:01 pm
On August 24, 2023, the Second Circuit affirmed the dismissal of state-law securities claims in Kirschner v. [read post]
13 Sep 2023, 10:59 am
Brooks—former Acting US Comptroller of the Currency—Rejoins O’Melveny [read post]
7 Sep 2023, 9:01 pm
On August 29, 2023, US federal banking regulators issued a proposal for long-term debt (“LTD”) requirements for certain midsize and larger US banking organizations (the “LTD Proposal”).1 The LTD Proposal is important because it would require many regional and larger banking organizations to issue significant amounts of LTD. [read post]
5 Sep 2023, 9:01 pm
ENDNOTE [1] The Federal Deposit Insurance Corporation (the FDIC), the Board of Governors of the Federal Reserve System (the Federal Reserve), and the Office of the Comptroller of the Currency (the OCC). [read post]
5 Sep 2023, 4:30 am
The Federal Reserve Board, Federal Deposit Insurance Corporation, and Office of the Comptroller of the Currency issued final guidance June 6, 2023, on managing risks associated with third-party relationships. [read post]
31 Aug 2023, 9:05 pm
The Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, and the Office of the Comptroller of the Currency jointly issued a proposed rule establishing a minimum long-term debt requirement for certain insured depository institutions. [read post]
31 Aug 2023, 8:25 pm
The Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, and the Office of the Comptroller of the Currency jointly issued a proposed rule establishing a minimum long-term debt requirement for certain insured depository institutions. [read post]
9 Aug 2023, 9:01 pm
On July 27, 2023, US federal banking regulators issued proposals to (i) significantly revise the risk-based regulatory capital requirements for certain midsize and larger US banking organizations (the “Capital Proposal”), and (ii) change the method for calculating the capital surcharge for globally systemically important banking organizations (“G-SIBs”) (the “G-SIB Surcharge Proposal”).1 These proposals are of critical importance because the amount of capital a… [read post]
31 Jul 2023, 9:01 pm
On July 27, 2023, the federal banking agencies released a lengthy proposal to revise the capital rules applicable to large banks and bank holding companies. [read post]
31 Jul 2023, 7:22 pm
Capital rules are set through regulation by the federal bank regulators—the Federal Deposit Insurance Corporation (FDIC), the Federal Reserve, and the Office of the Comptroller of the Currency (OCC)—and are modeled on international agreements made by the members of the Basel Committee on Bank Supervision. [read post]
24 Jul 2023, 8:59 am
In an unusual move, Laura Akahoshi, former Rabobank (the “Bank”) Chief Compliance Officer (“CCO”), filed on July 6, 2023 an opposition to the Office of the Comptroller of the Currency’s (“OCC”) dismissal of its own administrative enforcement proceeding against her. [read post]
17 Jul 2023, 8:08 am
The bank was also required to pay the CFPB penalties of $90 million, and a separate $60 million fine was imposed by the Office of the Comptroller of the Currency for violations of the laws related to overdraft fees. [read post]
