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The OCC has announced that Comptroller of the Currency Joseph Otting will step down on May 29, 2020 and Brian Brooks will become Acting Comptroller.

Brian currently serves as the OCC’s Chief Operating Officer and First Deputy Comptroller.  Before joining the OCC, Brian had a distinguished career in private legal practice and working in-house in…

The OCC has issued a final rule revising its regulation implementing the Community Reinvestment Act (CRA).  The final rule applies to national banks and federal savings associations.

Although the OCC’s proposed revisions were issued jointly with the FDIC, the FDIC did not join in the final rule.  FDIC Chairman Jelena McWilliams issued a statement in…

The Federal Reserve, OCC, FDIC, and NCUA have issued “Interagency Lending Principles for Offering Responsible Small-Dollar Loans.”  The agencies state that the principles are intended “to encourage supervised banks, savings associations, and credit unions to offer responsible small-dollar loans to customers for consumer and small business purposes.”

The issuance of the guidance follows…

The OCC has filed its opening brief in its appeal to the Second Circuit from the district court’s final judgment in the lawsuit filed by the New York Department of Financial Services (DFS) seeking to block the OCC’s issuance of special purpose national bank (SPNB) charters to non-depository fintech companies.

In May 2019, the district…

In our examination of two recent OCC BSA/AML consent orders, one with a bank and another with an individual in-house professional, we review the OCC’s allegations underlying the orders and how the OCC focuses on the core pillars of BSA/AML compliance when choosing to pursue enforcement.  We also discuss the takeaways for boards and management…

The CFPB, OCC, FDIC, Federal Reserve, and NCUA have issued a joint statement “to specifically encourage” banks, savings associations, and credit unions “to offer responsible small-dollar loans to both consumers and small businesses” in response to the COVID-19 outbreak.  The statement builds on the March 19 statement issued jointly by the OCC, FDIC, and Federal…

On March 5, 2020, the OCC issued a revised set of FAQs designed to supplement OCC Bulletin 2013-29 (Third-Party Relationships: Risk Management Guidance) issued on October 30, 2013.  The updated FAQs, issued via OCC Bulletin 2020-10, are intended to clarify the OCC’s existing third-party relationship guidance and reflect evolving industry trends.

The new bulletin…

The OCC and FDIC announced yesterday that they have extended the 60-day comment period for their joint proposal to revise their regulations implementing the Community Reinvestment Act that was published in the Federal Register on January 8, 2020.  As extended by 30 days, the comment period ends on April 8, 2020.

The California Reinvestment Coalition,…

We are joined by Diego Zuluaga, a Cato Institute policy analyst, for a discussion of the proposed changes.  After reviewing the current regulatory framework, we examine the proposal’s new qualifying activities criteria and approach to “branchless banking” in determining assessment areas, respond to criticism of its approach to public projects, look at the small bank…