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Tag Archives: OCC

OCC Acting Comptroller Woos Fintech Companies with Remarks on Online Lending

Posted in Regulatory Developments

On September 25, 2017, Acting Comptroller of the Currency Keith Noreika discussed online lending and innovation in his keynote remarks prepared for delivery to the Online Lending Policy Summit in Washington, D.C. Consistent with his previous remarks, the Acting Comptroller expressed his support for a regulatory environment that fosters responsible innovation and touted the growth… Read More

OCC Seeks Public Comment on the Volcker Rule

Posted in Regulatory Developments

Section 13 of the Bank Holding Company Act (the “Volcker Rule”) and its implementing regulations (the “Implementing Regulations”) generally prohibit banking entities from engaging in proprietary trading and from investing in, sponsoring, or having certain relationships with covered funds. On August 2, 2017, the OCC submitted to the Federal Register a notice requesting public comment on how… Read More

Acting Comptroller Endorses Fintech Charters

Posted in Regulatory Developments

In July 19, 2017 remarks prepared for delivery to the Exchequer Club in Washington, D.C., Acting Comptroller of the Currency Keith Noreika expressed his support for the Office of the Comptroller of the Currency’s efforts to establish national bank charters for financial technology companies. In endorsing the OCC’s so-called fintech charter, he noted that the… Read More

OCC Releases Semiannual Risk Perspective: Fintech is Risky?

Posted in Regulatory Developments

On July 7, 2017, the Office of the Comptroller of the Currency released its Semiannual Risk Perspective report identifying the risks faced by national banks and federal savings associations in the 12-month period ending December 31, 2016. The Report, which is intended to highlight key risk issues facing the federal banking system, noted that strategic, credit, operational… Read More

OCC Guidance Suggests Flexibility for Third-Party Risk Management

Posted in Regulatory Developments

On June 7, 2017, the Office of the Comptroller of the Currency issued frequently asked questions that supplement the OCC’s 2013 guidance entitled “Third-Party Relationships: Risk Management Guidance.” The 2013 Bulletin sets forth the OCC’s expectation for banks’ due diligence and ongoing monitoring of third-party service providers, including enhanced diligence and monitoring for third parties… Read More

Financial Services Report – Winter 2016

Posted in Arbitration, Auto Lending, CFPB, Credit Cards, Disparate Impact, Electronic Payments, Enforcement Actions, Fair Lending, Foreclosure, Military Issues, Mobile Payments, Mortgage, Payday Lending, Preemption, Privacy, Regulatory Developments, State Regulators, UDAAP

Hope you survived all of those awkward Thanksgiving holiday conversations—amazing how divided people are on whether the court got it right in the PHH case, isn’t it? So on we go into the holiday season, while visions of Dodd-Frank repeal dance in our heads. No long winter’s nap for the CFPB, not with the inauguration… Read More

EVENT: FinTech Companies and the OCC Special Purpose National Bank Charter

Posted in Events, Regulatory Developments

Thursday, December 8, 2016 11:00 a.m. – 12:00 p.m. PST 2:00 p.m. – 3:00 p.m. EST The Office of the Comptroller of the Currency (OCC) announced in a White Paper that it would begin considering applications from FinTech companies to become “special purpose national banks.” The White Paper includes information about the OCC’s supervisory expectations… Read More

OCC Announces Special Purpose National Bank Charter for FinTech Companies

Posted in Regulatory Developments

On December 2, 2016, Comptroller of the Currency Thomas Curry confirmed that the agency will begin considering applications from FinTech companies to become special purpose national banks, saying that the OCC will charter “financial technology companies that offer bank products and services and meet our high standards and chartering requirements.” The OCC simultaneously released a… Read More

OCC Lays Out Responsible Innovation Framework

Posted in Regulatory Developments

On October 26, 2016, the OCC issued its Recommendations and Decisions for Implementing a Responsible Innovation Framework (“Framework”). The Framework is a follow up to the OCC’s March 2016 white paper on Supporting Responsible Innovation in the Federal Banking System: An OCC Perspective (“White Paper”). The Framework reflects the comments received in response to the… Read More

Federal Banking Agencies Signal Enhanced Cyber Standards

Posted in Privacy, Regulatory Developments

On October 19, 2016, the Federal Deposit Insurance Corporation, the Federal Reserve Board and the OCC (collectively, the Agencies) released an Advanced Notice of Proposed Rulemaking (ANPR) laying out a framework for enhanced cyber risk management standards that the Agencies are considering requiring of certain “large and interconnected” financial institutions.  The Agencies have not yet proposed… Read More

CFPB, OCC, and Federal Reserve Propose Clarifications to Small Loan Exemption from HPML Appraisal Requirements

Posted in CFPB, Fair Lending, Mortgage, Regulatory Developments

In August 2016, the CFPB, the OCC, and the Board of Governors of the Federal Reserve System (together, the “Agencies”) jointly published in the Federal Register a notice of proposed rulemaking (NPR) to amend the Agencies’ respective regulations exempting certain small loans from the special appraisal requirements that apply to lenders in connection with making… Read More

Treasury Issues White Paper on Online Marketplace Lending

Posted in CFPB, Fair Lending

On May 10, 2016, the U.S. Department of the Treasury (“Treasury”) issued a white paper, entitled “Opportunities and Challenges in Online Marketplace Lending” (“White Paper”). The White Paper describes Treasury’s review of online marketplace lending and provides Treasury’s recommendations to the private sector and the federal government on how to encourage “safe growth” in the… Read More

CFPB Sends Industry Letter on TRID

Posted in CFPB, Mortgage

On October 1, regulators including the CFPB sent a letter to mortgage industry trade groups regarding TRID. The letter states that: “During initial examinations for compliance with the rule, the Bureau’s examiners will evaluate an institution’s compliance management system and overall efforts to come into compliance, recognizing the scope and scale of changes necessary for… Read More

OCC Takes a Page from the CFPB’s Playbook on Overdraft Programs

Posted in CFPB, Regulatory Developments

On February 11, 2015, the Office of the Comptroller of the Currency (OCC) issued an “updated” installment to the Comptroller’s Handbook in a new booklet entitled “Deposit-Related Consumer Credit.” In doing so, the OCC stole a page from the playbook used by the Consumer Financial Protection Bureau (CFPB) in its notice of proposed rulemaking on… Read More

Proposed Revisions to Community Reinvestment Act Q&A’s

Posted in Regulatory Developments

On September 10, 2014, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, “the Agencies”) requested comment on their  proposed revisions to interagency guidance on the Community Reinvestment Act (CRA), specifically to the Interagency Questions and Answers Regarding Community Reinvestment… Read More

Interagency Fair Lending Hot Topics

Posted in Auto Lending, CFPB, Mortgage

This Wednesday, October 22, 2014, federal enforcement and regulatory agencies are hosting an interagency webinar on emerging fair lending issues and hot topics. Representatives from seven agencies—the DOJ, CFPB, FDIC, OCC, Fed, HUD, and NCUA—will participate. The discussion includes the agencies’ expectations for institutions’ compliance management systems and fair lending risk assessments, fair lending risk associated with… Read More