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The Office of the Comptroller of the Currency (OCC) has taken another important step in addressing the rapidly expanding use of artificial intelligence in the banking industry. On November 4, 2026, the OCC issued a new supervisory framework designed to assist its bank examiners in evaluating banks’ use of what the agency, following the terminology adopted by the Trump Administration, calls “Super Intelligence” (SI).… Continue Reading

The Office of the Comptroller of the Currency (OCC) has filed on November 2,2026 its reply brief in support of its motion to dismiss, or alternatively transfer to the District of Columbia, a lawsuit brought by Oregon and nine other states challenging two OCC rules issued on May 15, 2026, concerning the preemption of state interest-on-mortgage escrow laws.… Continue Reading

The Office of the Comptroller of the Currency (OCC) is taking aim at another potential source of state regulatory interference with federally chartered financial institutions. In an October 29, 2026 letter to the Chair of the California Air Resources Board (CARB), Comptroller of the Currency Jonathan Gould urged California to exempt national banks and federal savings associations from two California climate-disclosure statutes.… Continue Reading

The ten states challenging the Office of the Comptroller of the Currency’s (OCC) new interest-on-escrow rules are urging a federal district court to reject the agency’s attempt to delay judicial review of those rules while the U.S. Supreme Court considers three petitions involving the preemption of state mortgage interest-on-escrow laws. In an October 23, 2026 filing the states argue that the Supreme Court proceedings discussed below will not resolve the central issues in their Administrative Procedure Act (APA) challenge, that an indefinite stay would harm both the states and consumers, and that the OCC has not demonstrated the hardship necessary to justify delaying the case.… Continue Reading

Oregon and nine other states argue that the OCC unlawfully preempted state interest-on-escrow laws, that Oregon is a proper venue, and that their challenge to the agency’s authority should proceed. The court expects to rule on the OCC’s motions by November 20.

Ten states challenging the Office of the Comptroller of the Currency’s (OCC) mortgage interest-on-escrow rules have opposed the agency’s motion to dismiss or transfer the case.… Continue Reading

The Office of the Comptroller of the Currency (OCC) has responded to the multistate lawsuit challenging its recent actions concerning mortgage escrow accounts with a motion that presents a merits argument as well as three distinct procedural paths: dismissal, transfer, or, potentially, a pause while the Supreme Court considers related preemption issues.… Continue Reading

The Independent Community Bankers of America (ICBA) has taken its long-running opposition to the Office of the Comptroller of the Currency’s (OCC) chartering of cryptocurrency companies to the courts.

On October 2, ICBA filed suit in the U.S. District Court for the District of Columbia against the OCC and Comptroller Jonathan Gould, challenging the OCC’s authority to charter non-depository, non-fiduciary cryptocurrency companies as national trust banks.… Continue Reading

Proposed guidance would require specific elements in bank policies and programs and could give added significance to FDIC’s proposed industry standard-setting organization

Executive Summary

The federal banking agencies have proposed new third-party risk management guidance that is more prescriptive than its emphasis on a “risk-based” approach might suggest. In addition to calling for risk-based oversight, the proposal identifies specific elements that banks should address in board-approved policies and throughout the life cycle of third-party relationships, including due diligence, contracting, ongoing monitoring, documentation, remediation, and termination.… Continue Reading

FinCEN and the federal banking agencies have clarified that Suspicious Activity Report (SAR) confidentiality does not prevent banks from communicating with customers about the underlying transactions or conduct that prompted concern, including explaining certain fraud-related restrictions or account closures.

The September 2 joint statement from FinCEN, the Federal Reserve, FDIC, NCUA and OCC does not change the Bank Secrecy Act or impose new supervisory requirements.… Continue Reading

First and Ninth Circuit decisions conflict with the Second Circuit, while the OCC has concluded that state escrow-interest laws are preempted

National bank preemption is headed toward another Supreme Court showdown. The Second Circuit has held that New York’s mortgage escrow-interest requirement is preempted, directly conflicting with the First Circuit’s decision upholding a comparable Rhode Island requirement and the Ninth Circuit’s decision allowing a similar California law to remain in effect.… Continue Reading