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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national banks
California, Illinois and New York File Suit Against OCC’s “Valid When Made” Final Rule
By Christina Grigorian on
Posted in Banking
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 Promulgates Final Rule on “Valid When Made”
By Christina Grigorian on
Posted in Banking
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
By Christina Grigorian & Lauren Haahr on
Posted in Banking
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 …