The Office of the Controller of the Currency (OCC) issues a semiannual risk perspective report that “addresses key issues facing banks, focusing on those that pose threats to the safety and soundness of banks and their compliance with applicable laws and regulations.” The most recent report “presents data in five main areas: the operating environment
Proposed New Breach Notification Rule for the Banking Industry
By Robinson+Cole's Data Privacy + Cybersecurity Team on
Posted in Enforcement + Litigation
The Office of the Comptroller of the Currency, Treasury (OCC), the Board of Governors of the Federal Reserve System (Board), and the Federal Deposit Insurance Corporation (FDIC) recently announced a “Notice of Proposed Rulemaking for the Computer-Security Incident Notification Requirements for Banking Organizations and Their Bank Service Providers.” This new rule would require a banking…
Morgan Stanley Settles with OCC for $60 Million
By Linn Foster Freedman on
Posted in New + Now
Morgan Stanley has settled claims by the Office of the Comptroller of the Currency (OCC) that it failed to properly decommission data centers that housed client data of its wealth-management operations two times—once in 2016 and once in 2019 for $60 million.
According to the OCC, Morgan Stanley “failed to effectively assess or address risks…
ILCs, the OCC, and the Future of Fintech Banking
By Norman Roos on
Posted in Enforcement + Litigation
Industrial Loan Companies (ILCs) are a different kind of financial institution. The ILC is a state-chartered FDIC-insured depository financial institution with certain advantages common to banks but without all of the corresponding regulatory overlay. This is one reason why aspiring fintech companies may consider foregoing the pursuit of a federal OCC “fintech” charter in favor…