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Last week, the OCC, Federal Reserve Board, and FDIC issued proposed guidance for banking organizations on managing risks associated with third-party relationships, including those with financial technology-focused entities such as bank/fintech sponsorship arrangements.  The agencies have made clear that if banks have ineffective risk management processes, agency examiners will closely scrutinize their third-party risk management…

The Federal Reserve, FDIC, and OCC have released proposed interagency guidance for banking organizations on managing risks associated with third-party relationships, including relationships with financial technology-focused entities such as bank/fintech sponsorship arrangements.  The proposal is the first time that the three agencies have proposed third-party risk management guidance on an interagency basis.  Comments on the…

Mr. Dougherty recently authored an article calling for the OCC’s abolishment and merger into the Federal Deposit Insurance Corp.  After reviewing the history of the creation of the OCC and Federal Reserve Banks, we examine and debate Mr. Dougherty’s arguments in support of his position.  We also discuss and respond to Mr. Dougherty’s criticism of…

On May 19, 2021, the House Financial Services Committee will hold a hearing, “Oversight of Prudential Regulators: Ensuring the Safety, Soundness, Diversity, and Accountability of Depository Institutions.”  The scheduled witnesses are:

  • Todd Harper, Chairman, National Credit Union Administration
  • Michael Hsu, Acting Comptroller of the Currency, Office of the Comptroller of the Currency
  • Jelena McWilliams,

…

Recently, federal agencies proposed revisions to the Interagency Questions and Answers Regarding Flood Insurance.  The agencies are the Comptroller of the Currency, Farm Credit Administration, FDIC, Federal Reserve Board, and National Credit Union Administration (Agencies).  The proposed Q&As will supplement the proposed Q&As issued by the Agencies in July 2020.  Those proposed Q&As contained…

In what could be an important step towards needed regulatory updating to accommodate the growing use of artificial intelligence (AI) by financial institutions, the CFPB, FDIC, OCC, Federal Reserve Board, and NCUA issued a request for information (RFI) regarding financial institutions’ use of AI, including machine learning (ML).  Comments on the RFI must be received…

On February 2, 2021, the Federal Reserve (“Fed”) announced that the launch date for its instant payments platform—FedNow—would be sooner than originally expected.  The announcement narrows the delivery timeframe by a full year.

FedNow provides interbank clearing and settlement, which enables funds to be transferred between banks and credited to accounts in near…

On Monday, the FRB, FDIC, and OCC issued a “Statement on LIBOR Transition” that encourages banks to transition away from the London Inter-Bank Offered Rate (LIBOR) as soon as possible, and in any event by December 31, 2021.    

The agencies indicate that the LIBOR administrator has announced it will consult on its intention…

The Biden transition has announced the members of its agency review teams.

The team leaders include the following individuals:

CFPB.  The team will be led by Leandra English, who is currently with the New York Department of Financial Services.  As our blog readers may recall, Ms. English was appointed CFPB Deputy Director by…