In October 2025, the Bank Policy Institute (BPI) issued a series of letters opposing efforts by several digital asset and payment firms to secure federal banking charters from the Office of the Comptroller of the Currency (OCC). BPI raised concerns that these companies are seeking trust charters even though, in…
On October 27, 2025, the Office of the Comptroller of the Currency (OCC) announced that it is seeking public comment on its proposal to eliminate certain recovery planning guidelines applicable to insured national banks, federal savings associations, and federal branches of foreign banks with at least $100 billion in assets….
In recent remarks delivered at the U.S. Chamber of Commerce Capital Markets Summit, Acting Comptroller of the Currency, Rodney E. Hood, outlined the OCC’s strategic priorities for building a resilient and revitalized federal banking system. Addressing an audience that included leaders from across the financial and business sectors, Acting Comptroller…
On December 8, 2021, the Acting Comptroller of the Currency, Michael J. Hsu, gave remarks before the Consumer Federation of America’s 34th Annual Financial Services Conference where he expressed the Office of the Comptroller of the Currency’s (OCC) push for bank overdraft reform to benefit financially vulnerable consumers. Hsu opined…
In August 2021, the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), and the Board of Governors of the Federal Reserve System (the Federal Reserve and, collectively with the OCC and the FDIC, the Agencies) released a joint bulletin titled “Conducting Due Diligence on…
On September 9, the Office of the Comptroller of the Currency (OCC) announced that it issued a $250 million civil money penalty against a national bank for alleged deficiencies in the bank’s home lending loss mitigation program, and for purportedly failing to meet its obligations under a 2018 consent order…
On August 30, 2021, the Department of Justice (DOJ) announced that, together with Office of the Comptroller of the Currency (OCC), it reached a settlement with a bank, resolving allegations that the bank engaged in lender discrimination in the Houston, Texas area. In 2017, the OCC initiated a fair lending examination…
On May 11, 2021, in a 52-47 vote, the United States Senate passed a Congressional Review Act resolution to revoke the Office of the Comptroller of the Currency’s (OCC) True Lender Rule. The Congressional Review Act, passed in 1996, permits Congress to pass a joint resolution of disapproval that, with…
On January 19, 2021, the Consumer Financial Protection Bureau (CFPB) issued a new final rule implementing the Fair Debt Collection Practices Act (FDCPA). According the CFPB’s press release, the purpose of the new final rule is to “clarif[y] the differences between regulations and supervisory guidance.” Specifically, “supervisory guidance does not…
As LenderLaw Watch previously reported, the Office of the Comptroller of the Currency (OCC) issued its final rule on the True Lender doctrine in October 2020, addressing ambiguity in federal law and establishing that a national bank is the “true lender” of a loan when, as of the date of…
On November 20, 2020, the Office of the Comptroller of the Currency (OCC) issued a proposed rule with the objective of ensuring banks offer fair access to financial services. Certain banks have received significant political pressure from various for-profit and not-for-profit organizations to deny financial services to customers in certain…
On November 5, 2020, the Federal Register published five federal financial regulatory agencies’ invitation for comment on a notice of proposed rulemaking (NPR) that would codify the agencies’ Interagency Statement Clarifying the Role of Supervisory Guidance, as amended, which was issued on September 11, 2018 (2018 Statement). The 2018 Statement…
As Lender Law Watch previously reported, in July 2020, to resolve the legal uncertainty discouraging many banks and companies from entering into partnerships to offer loans to consumers, the OCC issued its proposed true lender rule to address the question of which entity makes a loan when the “loan is…
On August 20, 2020, seven states – California, Illinois, Massachusetts, Minnesota, New Jersey, New York, and North Carolina – and the District of Columbia (together, the States) filed suit against the Federal Deposit Insurance Corporation (FDIC) in the U.S. District Court for the Northern District of California. The lawsuit, captioned…
The Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) issued Final Rules last month in an effort to address the “legal confusion” regarding the impact of the permissible interest when a bank transfers a loan to a third party. These Final Rules are…
On May 15, 2020, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (collectively, Regulators), proposed a new final interim rule “that temporarily revises the supplementary leverage ratio calculation for depository institutions,” in order to “strengthen…
Last week, the Office of the Comptroller of the Currency (OCC) and Federal Deposit Insurance Corporation (FDIC) each issued a proposed rule designed to clarify that interest rates that are valid when a loan is made remain valid when the loan is transferred or sold. Together, the proposed rulemaking would…
On March 19, 2019, the Office of the Comptroller of the Currency (OCC) announced that it had entered into a Consent Order with a major mortgage lender over allegations that the lender did not adequately ensure that its relationship loan pricing program was offered to all eligible customers, resulting in adverse…
On July 20, 2018, the Office of the Comptroller of the Currency (OCC) and Consumer Financial Protection Bureau (CFPB) reached a $30 million settlement with a South Dakota bank over allegations that the bank had engaged in deceptive practices with respect to its overdraft services in violation of Section 5 of the Federal Trade…
On May 1, 2018, the Office of the Comptroller of the Currency (OCC) entered into a consent order with a national bank for deceptive marketing and banking practices that allegedly resulted in violations of federal law. According to the consent order, the OCC alleged that the bank had violated Section…