Insights

Fast Company: Silicon Valley Bank: An ‘It’s a Wonderful Life’ bank run for the digital age
In the News Strategy & Advisory
Federal Reserve Hardens Stance Towards Crypto, Denies Bank Membership
Blog Strategy & AdvisoryWhat’s Happening
Federal Reserve (FRB) denies membership and master account application for state-chartered Custodia Bank with crypto-focused business model
FRB presumptively prohibits banks it supervises from holding crypto as principal…

OCC Acting Comptroller Discusses “Too Big to Manage” Banks, Four-Step Escalation Framework
Blog Strategy & Advisory, Litigation Support & Enforcement
Acting Comptroller of the Currency Michael Hsu presents a framework for scrutinizing banks viewed as “too big to manage.”
Hsu describes a four-step escalation framework for supervisory issues, with a “credible threat of restrictions…

Banking Regulators Send Strong Warning About Crypto Risks
Blog Strategy & Advisory, Risk Management & Compliance
Federal banking agencies encourage banks to monitor crypto risks, stress importance of keeping crypto sector risks isolated from broader financial system.
Regulators view open, public or decentralized networks as highly likely to be inconsistent…

Regulators Warn on Interest Rate Risks, Banks Should Prepare for Scrutiny
Blog Risk Management & Compliance
Rising interest rates are adversely affecting bank investment portfolios, leaving banks with a difficult set of choices.
Regulators increasingly are expressing concern with the effect of interest rate risk.
Banks must ensure their…

CFPB Begins 1033 Rulemaking to Set Standards for the Use of Consumer Financial Data
Patomak Post Risk Management & Compliance
The CFPB rulemaking intends to provide consumers greater control over personal data to help accelerate the shift toward open banking and more decentralized markets.
The proposed rule would move U.S. privacy regulations closer to Europe's…

Office of the Comptroller of the Currency Orders Blue Ridge Bank to Improve its Third-Party Risk Management
Patomak Post Litigation Support & EnforcementOn August 29, Blue Ridge Bank, National Association, disclosed to the U.S. Securities and Exchange Commission a formal agreement with the Office of the Comptroller of the Currency (OCC). The OCC announced the agreement on October 20, detailing…

Fifth Circuit Issues Decision on CFPB Funding, Vacates 2017 Payday Lending Rule
Patomak Post Strategy & Advisory, Risk Management & Compliance
Ruling finds CFPB funding unconstitutional, seeks to distinguish CFPB funding from other self-funded agencies.
Fifth Circuit vacates 2017 Payday Lending Rule on grounds that it was promulgated using funds obtained outside of the Congressional…

Mortgage Risk Redux in This (or the Next) Recession
Patomak Post Risk Management & ComplianceWhile a recession is a mere technicality, inflation and other adverse economic factors are already working to make the risks in the mortgage industry that have accumulated over a 13-year expansion more likely to become reality. How nearly $12…

Federal Reserve Board Provides Additional Information for Banks Interested in Crypto-Related Activities
Patomak Post Risk Management & Compliance, Strategy & Advisory
Federal Reserve outlines step-by-step process for banks considering crypto-related activities.
Despite efforts to add controls to crypto activities, several senators still believe crypto-related activities pose too great a risk for national…