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Greg leverages his broad experience and pragmatic approach, bringing a wealth of knowledge, business insight and practical problem-solving skills to efficiently manage transactions and advise clients in an evolving legal landscape. He combines his corporate and transactional experience with a robust knowledge of bank regulatory issues to provide valued legal solutions for financial institutions, financial technology companies and other businesses. Greg often works closely with clients to design and implement internal policies and procedures and contractual safeguards in commercial arrangements in connection with corporate and regulatory requirements and risk management best practices.

On December 7, the Office of the Comptroller of the Currency (OCC) published the fall edition of its Semiannual Risk Perspective, which discusses key issues facing banks. From the OCC’s perspective, the overall strength of the banking system remains sound and recessionary pressures appear to be easing. The OCC notes that, while many economists had predicted a decline, gross domestic product increased at an annual rate of 2.1% in the second quarter of 2023, slowing just slightly from the first quarter’s 2.2% pace. However, the OCC also emphasized that inflation remains elevated and a slowing labor market, declining savings, and higher interest rates could cause financial stress to borrowers.

On October 24, the Federal Reserve Board (Fed), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the agencies) finally issued their long-awaited final rule modernizing how they assess lenders’ compliance under the Community Reinvestment Act (CRA). The CRA was enacted in 1977 to address systemic inequities in access to credit and encourages banks to meet the credit needs of the entire community, including low- and moderate-income (LMI) communities, consistent with safety and soundness principles. The last meaningful, comprehensive revision to the CRA regulations occurred in 1995.

On August 2, the Federal Financial Institutions Examination Council (FFIEC) announced updates to certain sections and examination procedures in the FFIEC Bank Secrecy Act/Anti-Money Laundering Examination Manual (Manual). The Manual instructs examiners on how to assess a bank’s anti-money laundering/countering the financing of terrorism (AML/CFT) program and its compliance with other AML/CFT regulatory requirements. The FFIEC cautions that the updates should not be seen as new instructions or an increased focus on certain areas, but instead as offering further transparency into the examination process and supporting risk-focused examination work.

On July 28, the Board of Governors of the Federal Reserve System (Federal Reserve), Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, and the National Credit Union Administration (NCUA) (collectively, the agencies) issued an addendum to the agencies’ joint policy statement on funding and liquidity risk management, which advises depository institutions to assess and maintain a broad range of funding sources that can be accessed in adverse circumstances. Specifically, the agencies advised depository institutions to regularly test any contingency borrowing lines to ensure the institution’s staff are well versed in how to access them and that they function as envisioned.

Today, the Federal Deposit Insurance Corporation (FDIC) issued a letter to financial institutions (FIL-37-2023) regarding the proper way to report estimated uninsured deposits in accordance with the instructions to the Consolidated Reports of Condition and Income (Call Report). FIL-37-2023 does not impact institutions with less than $1 billion in total assets that do not report estimated uninsured deposits.

On July 18, Office of the Comptroller of the Currency (OCC) Senior Deputy Comptroller for Large Bank Supervision Greg Coleman testified on OCC supervision of climate-related financial risks before the U.S. House of Representatives’ Committee on Financial Services’ Subcommittee on Financial Institutions and Monetary Policy.

At a Peterson Institute for International Economics event on June 22, Federal Deposit Insurance Corporation (FDIC) Chairman Martin Gruenberg announced that the FDIC — along with the Board of Governors of the Federal Reserve System (Federal Reserve) and the Office of the Comptroller of the Currency (OCC) — will issue an interagency notice of proposed

At a Brookings Institution event on June 20, Assistant Attorney General Jonathan Kanter, a top antitrust official for the U.S. Justice Department (DOJ or Department), announced that the Department will reassess its approach to bank merger enforcement given current market realities. Specifically, the Department will assess whether the factual and economic assumptions underlying its 1995 Bank Merger Guidelines are adequate to measure today’s competition.

On June 14, the Office of the Comptroller of the Currency (OCC) published the spring edition of its Semiannual Risk Perspective, which discusses key issues facing banks. The good news is that the federal banking system saw historic growth in net interest income in 2022. However, rising interest rates weigh on other aspects of bank performance, such as noninterest income, as mortgage activity continues to slow.

On June 9, the Office of the Comptroller of the Currency (OCC) announced it is requesting information for a proposed annual survey aimed at understanding and measuring the public’s trust in banking and banking supervision. The OCC is inviting various stakeholders to comment on the survey’s scope and ways to track public trust over time.