The National Risk Committee (NRC) of the Office of the Comptroller of the Currency (OCC) published its Semiannual Risk Perspective Fall 2020 on November 9. The semiannual report included numerous findings with respect to the health of the nation’s national banks and federal savings banks, including the following:
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federal savings associations
California, Illinois and New York File Suit Against OCC’s “Valid When Made” Final Rule
On July 29, the Attorneys General for the States of California, Illinois and New York (State AGs) filed suit seeking declaratory and injunctive relief in the US District Court for the Northern District of California (Complaint) against the Office of the Comptroller of the Currency (OCC), the primary federal regulator for national banks and federal savings banks (each, a Bank), in connection with the OCC’s issuance of its final “valid when made” rule that was effective on August 3 (VWM Rule).
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OCC Publishes Proposed Rule Regarding “True Lender”
On July 20, the Office of the Comptroller of the Currency (OCC), the primary federal regulator for national banks and federal savings banks (each, a Bank), issued a proposed rule regarding when a Bank is the “true lender” in connection with a loan (Proposed Rule).
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OCC Promulgates Final Rule on “Valid When Made”
On June 2, the Office of the Comptroller of the Currency (OCC) promulgated its final rule confirming the longstanding banking principle that a loan that is valid when made is enforceable by any subsequent assignee (the Final Rule). The Final Rule applies to national banks and federal savings banks.
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OCC Issues FAQs on Managing Third-Party Relationships
On June 7, the Office of the Comptroller of the Currency (OCC) issued frequently asked questions (FAQs) to supplement OCC Bulletin 2013-29, “Third-Party Relationships: Risk Management Guidance,” which was originally issued on October 30, 2013. These FAQs address questions from national banks and federal savings associations. The FAQs and underlying OCC Bulletin 2013-29 apply to …
OCC Revises Residential Real Estate Lending Guidance in Comptroller’s Handbook
On June 15, the Office of the Comptroller of the Currency (OCC) issued the “Residential Real Estate Lending” booklet of the Comptroller’s Handbook. This revised booklet replaces the “Real Estate Loans” booklet issued in March 1990 (and examination procedures issued in March 1998). The revised booklet also replaces section 212, “One- to Four-Family Residential Real Estate Lending,” issued in February 2011 as part of the former Office of Thrift Supervision (OTS) Examination Handbook for the examination of federal savings associations (FSAs).
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