Brendan Clegg
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Articles by Brendan Clegg
Federal Financial Agencies Shift Third Party Risk Management Toward A Tailored Risk Based Approach
On September 11, 2026, the FDIC, Federal Reserve, OCC, and NCUA (together, the “Agencies”) issued proposed third-party risk management guidance1 (the “TPRM Guidance”) outlining a principles-based approach designed to assist banks and credit unions (together, “institutions”) in tailoring their third-party risk management practices to the risks of individual relationships.
Federal Financial Agencies Shift Third Party Risk Management Toward a Tailored Risk Based Approach
On September 11, 2026, the FDIC, Federal Reserve, OCC, and NCUA (together, the “Agencies”) issued proposed third-party risk management guidance1 (the “TPRM Guidance”) outlining a principles-based approach designed to assist banks and credit unions (together, “institutions”) in tailoring their third-party risk management practices to the risks of individual relationships.
OCC and FDIC Overhaul Bank Supervision, MRAs, and Enforcement Framework
On August 27, 2026, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) (together, the Agencies) issued a final rule (the Final Rule) adopting a regulatory definition for the term “unsafe or unsound practice” and revising the supervisory framework for issuing matters requiring attention (MRAs), as part of the Agencies’ more comprehensive efforts to focus supervisory and institution attention on material financial risks.
Reforms To Bank Agency Appeal Processes May Boost Usage
By Brendan Clegg ( February 26, 2026, 4:58 PM EST) -- Although the Office of the Comptroller of the Currency, Federal Deposit Insurance Corp. and Federal Reserve have each been required by federal statute to have an independent appeals process since 1994, the procedures implemented by these agencies have been underutilized since their inception.[1]... Law360 is on it, so you are, too.
What the Agencies’ Supervisory Changes Mean for Bank Directors
In October 2025, the federal regulators announced a significant shift in their respective approaches to bank supervision. The Office of the Comptroller of the Currency and the Federal Deposit Insurance Corp. issued a joint proposed rule that will establish a regulatory definition for the term “unsafe or unsound practice” and formalize standards for issuing matters requiring attention (MRAs).
What To Note In OCC, FDIC Plan To Standardize Supervision
By Brendan Clegg ( November 7, 2025, 4:56 PM EST) -- On Oct. 7, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corp. issued a joint notice for a proposed rule to establish a uniform definition for the term "unsafe or unsound practice" for purposes of the agencies' enforcement and supervisory authority under Title 12 of the U.S. Code, Section 1818, and to revise the supervisory framework for issuing matters requiring attention, or MRAs....
What To Note In OCC, FDIC Plan To Standardize Supervision
By Brendan Clegg ( November 7, 2025, 4:56 PM EST) -- On Oct. 7, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corp. issued a joint notice for a proposed rule to establish a uniform definition for the term "unsafe or unsound practice" for purposes of the agencies' enforcement and supervisory authority under Title 12 of the U.S. Code, Section 1818, and to revise the supervisory framework for issuing matters requiring attention, or MRAs....
Ban On Reputation Risk May Help Bank Enforcement Defense
By Brendan Clegg ( April 18, 2025, 10:06 AM EDT) -- In recent weeks, both acting Comptroller of the Currency Rodney Hood and acting Federal Deposit Insurance Corp. Chairman Travis Hill have publicly committed their agencies to stop considering reputation risk as a part of their supervision of national banks and state nonmember banks, respectively.... Law360 is on it, so you are, too.
Ban On Reputation Risk Assessment May Be Boon For Banks
By Brendan Clegg ( April 18, 2025, 10:06 AM EDT) -- In recent weeks, both acting Comptroller of the Currency Rodney Hood and acting Federal Deposit Insurance Corp. Chairman Travis Hill have publicly committed their agencies to stop considering reputation risk as a part of their supervision of national banks and state nonmember banks, respectively.... Law360 is on it, so you are, too.
Anticipating Jarkesy's Effect On Bank Agency Enforcement
By Brendan Clegg ( October 22, 2024, 4:38 PM EDT) -- The U.S. Supreme Court's June decision in SEC v. Jarkesy,[1] affirming the right of the defendants to a jury trial in federal court when the U.S. Securities and Exchange Commission sought civil penalties for alleged securities fraud, could have far-reaching implications on the administrative enforcement process used by the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, and the Federal Reserve Board....
Anticipating Jarkesy's Effect On Bank Agency Enforcement
By Brendan Clegg ( October 22, 2024, 4:38 PM EDT) -- The U.S. Supreme Court's June decision in SEC v. Jarkesy,[1] affirming the right of the defendants to a jury trial in federal court when the U.S. Securities and Exchange Commission sought civil penalties for alleged securities fraud, could have far-reaching implications on the administrative enforcement process used by the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, and the Federal Reserve Board....
Anticipating Jarkesy's Effect On Bank Agency Enforcement
By Brendan Clegg ( October 22, 2024, 4:38 PM EDT) -- The U.S. Supreme Court's June decision in SEC v. Jarkesy,[1] affirming the right of the defendants to a jury trial in federal court when the U.S. Securities and Exchange Commission sought civil penalties for alleged securities fraud, could have far-reaching implications on the administrative enforcement process used by the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, and the Federal Reserve Board....
Supreme Court Decision Signals Changes for Bank Agency Enforcement Processes
Bank M&A Bank M&A topics will include balance sheet considerations for both the acquiring and acquired financial institutions such as deposits, capital adequacy, credit quality and more. Information around regulatory preparations and concerns as well as credit risks will also be addressed. Explore
Proposed Legislation Expands Enforcement Authority Against Bank Officers, Directors
The RECOUP Act (S.2190), which passed the Senate Banking Committee in June by a bipartisan 21-2 vote, would greatly expand the federal bank agencies’ authority to remove and permanently ban officers from the banking industry if it becomes law.
Federal Bank Regulators Set Out Regulatory Roadmap for Crypto-Assets | JD Supra
Our Financial Services & Products Group investigates the federal banking regulators’ roadmap for crypto-asset regulation in 2022 and a new OCC procedure national banks must comply with to conduct crypto-asset activities.
How Can Companies Use OFAC's New Guidance On Virtual Currency?
To print this article, all you need is to be registered or login on Mondaq.com. Executive Summary New guidance from the Office of Foreign Assets Control seeks to help companies in the virtual currency industry with four specific objectives. Our Financial Services & Products and International Trade & Regulatory Groups break down how the guidance can be used to comply and avoid sanctions.
How Can Companies Use OFAC’s New Guidance on Virtual Currency? | JD Supra
New guidance from the Office of Foreign Assets Control seeks to help companies in the virtual currency industry with four specific objectives. Our Financial Services & Products and International Trade & Regulatory Groups break down how the guidance can be used to comply and avoid sanctions.
Avoiding Pitfalls During Post-Pandemic Government Investigations | JD Supra
CSI: Confidential Supervisory Information is not a show many banks would enjoy watching, but it’s one of three areas our Financial Services & Products Group notes banks should keep in mind if they become the subject of subpoenas, document requests, examinations, or investigations by government agencies.
SEC Raises More Red Flags over Broker-Dealer AML Compliance | JD Supra
The SEC’s thoughts on anti-money laundering cost more than a penny stock. Our Financial Services & Products Group examines a new risk alert from the Division of Examinations and what it means for future enforcement.
Nevada Spousal Credit Sharing May Conflict With Federal Law
Law360 (September 11, 2019, 4:24 PM EDT) -- In just a few weeks, lenders may face a challenging circumstance in evaluating applications for credit from some Nevada borrowers. Can lenders comply with a new Nevada law that allows applicants with no credit history to use their spouse’s credit history without violating the Equal Credit Opportunity Act and Regulation B, federal laws that generally prohibit consideration of marital status in evaluating creditworthiness?
Don’t get burned by coming CDD rule
FinCEN’s issuance of the final customer due diligence (CDD) rule in May 2016 significantly altered the Bank Secrecy Act / Anti-Money Laundering (BSA/AML) compliance landscape.1 Insured depository institutions, among other covered financial entities, must comply with the rule by May 11, 2018. The rule will change banks’ day-to-day business operations by requiring risk-based procedures for conducting customer due diligence on all customers.
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