Insights

Office of the Comptroller of the Currency

OCC Acting Comptroller Discusses “Too Big to Manage” Banks, Four-Step Escalation Framework

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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…
Office of the Comptroller of the Currency

Banking Regulators Send Strong Warning About Crypto Risks

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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…
Office of the Comptroller of the Currency

Regulators Warn on Interest Rate Risks, Banks Should Prepare for Scrutiny

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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…
Office of the Comptroller of the Currency

Office of the Comptroller of the Currency Orders Blue Ridge Bank to Improve its Third-Party Risk Management

On 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…
Office of the Comptroller of the Currency

Mortgage Risk Redux in This (or the Next) Recession

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While 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…
Office of the Comptroller of the Currency

Our Op-Ed in the American Banker: An Unworkable Compromise on Stablecoins

The crypto industry yearns for legislative clarity on stablecoins, but the industry and consumers may be better off under the status quo than a flawed compromise. A one-size-fits-all approach could squash innovation. Expanding Federal…
Office of the Comptroller of the Currency

Federal Reserve Board Provides Additional Information for Banks Interested in Crypto-Related Activities

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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…
Office of the Comptroller of the Currency

Keith Noreika Featured on the Consumer Finance Monitor Podcast: Innovation, True Lender, and Issues Facing Banks Today

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I recently sat down with Alan Kaplinsky of Ballard Spahr to discuss innovation, “true lender,” and other issues facing financial institutions today for the Consumer Finance Monitor podcast. While the conversation covered a lot of ground,…
Office of the Comptroller of the Currency

Senators Pressure OCC to Rescind Crypto Bank Guidance, Adding Regulatory Uncertainty

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Senators ask the Office of the Comptroller of the Currency (OCC) to rescind interpretive letters clarifying banks’ authority to engage in crypto-related activities. Despite efforts adding controls to crypto activities, senators still…
Office of the Comptroller of the Currency

Banking Regulators Propose CRE Loan Policy Update, Signal Concerns for Upcoming Business Cycle

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Updated statement signals concern from agencies about the impact of slowing economy on CRE lenders and borrowers. Proposed statement affirms that lenders will not be criticized for implementing certain CRE loan workouts and accommodations. …