Supervision

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OCC-supervised institutions with $100 billion or more in average total consolidated assets must be adequately prepared to mitigate severe financial and non-financial risks.

By Arthur S. Long, Pia Naib, and Deric Behar

On July 3, 2024, the Office of the Comptroller of the Currency (OCC) issued a proposal (the Proposal) to revise its enforceable recovery planning guidelines1 (the Guidelines) for certain large insured national banks, insured federal savings associations, and insured federal branches of non-US banks (together…

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Insured depository institutions with $50 billion to less than $100 billion in average total assets are subject to new resolution reporting standards, with enhanced reporting for those with average total assets of $100 billion or more.

By Arthur S. Long, Pia Naib, and Deric Behar

On June 20, 2024, the Federal Deposit Insurance Corporation (FDIC) issued a final rule (the Rule) updating the FDIC’s resolution plan regulations1 for covered insured depository institutions (CIDIs).2 The revisions are…

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FINRA’s guidance sheds further light on the new rule, which will permit firms to elect “non-branch” designation for a private residence where an associated person conducts specified supervisory activities.

By Marlon Q. Paz, Naim Culhaci, and Donald Thompson

The Financial Industry Regulatory Authority (FINRA) has issued much-needed guidance on residential supervisory locations (RSLs). The new guidance supplements its January 23, 2024, Regulatory Notice 24-02 (Reg. Notice 24-02) on new supplementary material .19 under FINRA Rule…

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The new rule establishes criteria for firms to elect “non-branch” designation for a private residence where an associated person engages in specified supervisory activities.

By Marlon Q. Paz, Naim Culhaci, Donald Thompson, and Jessmine Lee

On January 23, 2024, the Financial Industry Regulatory Authority (FINRA) issued Regulatory Notice 24-02 (Reg. Notice 24-02), announcing guidance and effective dates on two recently approved supplementary materials under FINRA Rule 3110:

  1. FINRA Rule 3110.19, enabling firms to
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