Tag Archives: OCC

Interagency Guidance for Financial Institutions on Coronavirus Disease-Related Loan Modifications

On Sunday night, March 22, 2020, the federal banking agencies (OCC, FDIC, NCUA, Federal Reserve), the Consumer Financial Protection Bureau and the State Conference of Bank Supervisors issued an Interagency Statement on Loan Modifications and Reporting for Financial Institutions Working with Customers Affected by the Coronavirus. The Guidance does two key things: 1. Short-term loan … Continue Reading

FDIC and OCC Extend Comment Period for Proposed Changes to the Community Reinvestment Act Regulations

On Feb. 19, the Federal Deposit Insurance Corporation and Office of the Comptroller of the Currency (collectively, the “Agencies”) announced an extension of the public comment period on the Notice of Proposed Rulemaking (NPRM) to amend the regulations implementing the Community Reinvestment Act (CRA). The Agencies announced they are extending the public comment deadline to … Continue Reading

NY Governor’s Proposed Budget Forecasts Increased Regulation of Fintech

In his proposed budget for fiscal year 2017-2018, New York Governor Andrew Cuomo advanced changes to the New York Banking Law that would give the Department of Financial Services (NY DFS) increased licensing authority over online and marketplace lenders.[1] The proposed budget would prohibit any entity from engaging in the business of making loans in … Continue Reading

OCC Consideration of Special Purpose Fintech Charters Draws Rapid Reaction for State Banking Regulators

On Dec. 2, 2016, the Office of the Comptroller of the Currency (OCC) published a preliminary proposal to create a national bank charter for financial technology companies (fintech). The OCC’s rationale in support of the proposal was that such a charter could promote the safety and soundness of fintech institutions, bring greater legal and regulatory … Continue Reading

OCC Lays Groundwork for National Fintech Charters

Recently, the OCC has begun to lay the groundwork for future national fintech charters, relying on an existing federal law which grants the OCC receivership powers over non-depositary financial institutions, which would permit the OCC to grant charters to fintech companies without their having to obtain insurance from the FDIC. In a release issued on … Continue Reading

OCC Forum on Responsible Innovation

On June 23, 2016 the Office of the Comptroller of the Currency (OCC) hosted the Forum on Responsible Innovation in the Federal Banking System in Washington, D.C. Hundreds of industry stakeholders gathered to discuss “Responsible Innovation,” fintech, and the role of the OCC in regulating the financial industry as it evolves.  The forum addressed reaction … Continue Reading

Nonbank Fintech: Regulatory Uncertainty as Innovation Flourishes

At the end of March, the OCC issued a whitepaper setting out the principles that it will use to guide the development of a framework to analyze innovations in the banking sector of financial technology, or “fintech” for short.  The paper defined and encouraged “responsible innovation,” and discussed both benefits and risks arising from the … Continue Reading

OCC Issues New Guidance and Policies on Enforcement Actions and Civil Monetary Penalties Against Institutions and Individuals

The Office of the Comptroller of the Currency (“OCC”) recently released new guidance on the process it uses when considering enforcement actions against banking institutions and individuals for potential non-compliance with Bank Secrecy Act (“BSA”) compliance program requirements and anti-money laundering (“AML”) rules.  At the same time, the OCC also issued a revised policy for … Continue Reading
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