In testimony before the House Financial Services Committee, Comptroller of the Currency Joseph Otting detailed key credit, interest rate, operational and compliance risks faced by the banking industry and identified the top priorities for the Office of the Comptroller of the Currency ("OCC").
Mr. Otting's priorities include:
modernizing the Community Reinvestment Act ("CRA") framework, including by (i) examining the scope of activities that qualify for CRA consideration, (ii) reevaluating the use of assessment areas and (iii) establishing clear thresholds for evaluating CRA performance;
encouraging banks to responsibly offer short-term, small-dollar installment loans (see previous coverage);
reforming Bank Secrecy Act/Anti-Money Laundering compliance obligations to reduce regulatory burdens and allow for effective protection against illicit activity;
simplifying regulatory capital rules and the Volcker Rule (see coverage of the "Economic Growth, Regulatory Relief, and Consumer Protection Act" and regulators' proposal to amend Volcker regulations); and
improving the OCC's effectiveness and efficiency, including through improved utilization of technological tools.
Mr. Otting described how the financial system has "rebounded from the crisis," with "capital and liquidity at near historic highs" and more effective institutional risk management.
Cadwalader partners summarized key provisions of the Economic Growth, Regulatory Relief, and Consumer Protection Act.
Cadwalader attorneys reviewed the recent Federal Reserve proposal to revamp regulations implementing the Volcker Rule.
The Office of the Comptroller of the Currency reminded supervised banks of the "core principles" for responsible short-term, small-dollar installment lending.
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