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FDIC PROPOSED POLICY STATEMENT FOR CLIMATE-RELATED FINANCIAL RISK MANAGEMENT

The Federal Deposit Insurance Corporation has published a Proposed Policy Statement for Climate-Related Financial Risk Management. The seventeen-page proposal would provide a high-level framework for the safe and sound management of exposures to climate-related financial risks. Although all financial institutions, regardless of size, may have material exposures to climate-related financial risks, these draft principles are targeted at the largest financial institutions, those with over $100 billion in total consolidated assets. The draft principles are intended […]

COMPUTER SECURITY INCIDENTS – WHO TO CONTACT?

On November 17, 2021, the Office of the Comptroller of the Currency (OCC), Treasury; the Board of Governors of the Federal Reserve System (Board); and the Federal Deposit Insurance Corporation (FDIC) released a final rule that requires a banking organization to notify its primary federal regulator of any “computer-security incident” that rises to the level of a “notification incident,” as soon as possible and no later than 36 hours after the banking organization determines that a notification […]

PLAN FOR PROPERTY APPRAISAL AND VALUATION EQUITY

Over the past few years, stories have circulated about properties being appraised for less than typical market value. When the property is reappraised, after the homeowner removes all evidence of his or her blackness, the property appraises for market value. On October 14, 2020, it was reported that an unnamed individual (Complainant) filed a complaint against JPMorgan Chase Bank, N.A. with the United States Department of Housing and Urban Development (“Department”), alleging Complainant was injured […]

INTERAGENCY STATEMENT ON SPECIAL PURPOSE CREDIT PROGRAMS

On February 22, 2022, The Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), the Office of the Comptroller of the Currency (OCC), the Consumer Financial Protection Bureau (CFPB or Bureau), the Department of Housing and Urban Development (HUD), the Department of Justice (DOJ), and the Federal Housing Finance Agency (hereafter, the agencies) issued an interagency statement to remind creditors of the ability […]

FDIC STATEMENT OF 2022 PRIORITIES

On February 7, 2022, FDIC Acting Chairman Martin J. Gruenberg released a statement of the FDIC’s priorities for the coming year. Among other items, the list includes: Strengthen Community Reinvestment Act (CRA): The federal banking agencies – the Federal Reserve, the Comptroller of the Currency, and the FDIC – have been working on a major revision of the rule implementing CRA. CRA requires banks to meet the credit needs of all the communities they serve, including […]