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Commentary by Steven Lofchie

The Government Accountability Office ("GAO") reported that community banks, credit unions and industry associations cited an increase in the compliance burden from the Dodd-Frank Act. The GAO report stated that the full impact of the Dodd-Frank Act "remains uncertain because many of its rules have yet to be implemented and insufficient time has passed to evaluate others." The GAO report examined: (i) regulatory analyses by federal agencies and interagency coordination, and (ii) the impact of selected Dodd-Frank provisions and related implementing rules on financial stability. From interviews

The Board of Governors of the Federal Reserve System, the FDIC and the Office of the Comptroller of the Currency ("OCC" and, collectively, the "agencies") expressed their support of the March 2014 guidance on the "external audits of banks" by the Basel Committee on Banking Supervision ("BCBS"). While recognizing that the existing practices in the United States are broadly consistent with the BCBS guidance, the agencies also acknowledged that "differences exist between the standards and practices followed in the United States and the principles and expectations" in the BCBS guidance. For that

The Office of the Comptroller of the Currency reminded national banks and federal savings associations of their obligations concerning (i) the maintenance of records, (ii) records retention and (iii) examiner access.