On September 18, 2023, the Federal Reserve, Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency jointly published and sought comments on a proposal to implement new, standardized capital requirements that would, among other things, increase capital requirements for banks with $100 billion or more in total assets.… Continue Reading

This is our third blog post on the final rule issued on October 24, 2023 by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency amending their regulations implementing the Community Reinvestment Act (“CRA”) (the “Final Rule”). … Continue Reading

This is our second blog post on the final rule issued on October 24, 2023 by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency amending their regulations implementing the Community Reinvestment Act (“CRA”) (the “Final Rule”). … Continue Reading

On October 24, 2023,  the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency issued a final rule amending their regulations implementing the Community Reinvestment Act (“CRA”) (the “Final Rule”).  The Final Rule marks the first substantial revision to the CRA regulations in nearly thirty years. … Continue Reading

On October 19, 2023, the Consumer Financial Protection Board (“CFPB”) released a proposed rule that, if enacted, would grant consumers greater access rights to the data their financial institutions hold. Under the proposed Personal Financial Data Rights Rule (the “Proposed Rule”), bank customers nationwide would have privacy rights similar to what is afforded under the dozen state privacy laws that have been enacted in recent years. … Continue Reading

On March 30, 2023, the White House endorsed several proposals to strengthen regulatory requirements for the banking industry in the wake of the Silicon Valley Bank and Signature Bank failures. This comes on the heels of President Biden’s March 13, 2023 remarks where he noted his intention to ask Congress and the banking regulators to “strengthen the rules for banks” to decrease the likelihood of similar failures in the future.… Continue Reading

On September 7, 2022, newly-appointed Vice Chair for Supervision at the Federal Reserve (the “Fed”), Michael S. Barr, gave a speech outlining his near-term goals and the “holistic approach” he intends to take to achieve them.  Building on the efforts made over the previous 12 years since the Global Financial Crisis to strengthen the banking system and oversight, Barr emphasized his top goals include making the financial system safer and fairer. … Continue Reading

As we previously reported, the Office of the Comptroller of the Currency (“OCC”) rescinded its 2020 Community Reinvestment Act (“CRA”) final rule (the “2020 CRA Final Rule” or the “Rescinded Rule”) in December 2021 and has since been operating under a CRA framework largely based on the OCC’s 1995 CRA rule (the “1995 Rule”), which was adopted jointly with the Federal Reserve and the FDIC. … Continue Reading

On December 18, 2020, the Office of the Comptroller of the Current (OCC), Federal Reserve Board (FRB), and Federal Deposit Insurance Corporation (FDIC) announced an interagency notice of proposed rulemaking that would require supervised banking organizations to provide notification of significant computer security incidents to their primary federal regulator.  Under the proposed rule, for incidents that could result in a banking organization’s inability to deliver services to a material portion of its customer base, jeopardize the viability of key operations of a banking organization, or impact the stability of the financial sector, the banking organization must notify its primary federal regulator no later than 36 hours after determining an incident has occurred. … Continue Reading