MVA attorneys Ed O'Keefe, John Stoker, and Kate Wellman authored "Banking Supervision and Enforcement Reform: Early Themes Emerging from New Standards," recently published in Reuters Legal and Westlaw Today. The article examines recent developments in federal banking supervision and enforcement and considers what those developments may mean for banks and other financial institutions navigating evolving regulatory expectations.
The article analyzes recent actions by the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), and the Board of Governors of the Federal Reserve System (Federal Reserve) as the agencies refocus supervision and enforcement on material financial risk and the effectiveness of risk management. It also examines how this shift is affecting matters requiring attention (MRAs), matters requiring immediate attention (MRIAs), and enforcement actions involving unsafe or unsound practices.
The article outlines several key themes, including:
- Federal banking agencies are increasingly focusing supervision and enforcement on material financial risk and effective risk management.
- Bank Secrecy Act (BSA) and anti-money laundering and countering the financing of terrorism (AML/CFT) compliance remain significant enforcement priorities.
- Capital, liquidity, financial condition, and other safety-and-soundness concerns remain relevant to regulatory scrutiny.
- Substantive legal violations may continue to support matters requiring attention, matters requiring immediate attention, and other supervisory actions.
- Differences among the OCC, FDIC, and Federal Reserve approaches could lead to divergent supervisory outcomes.
- Informal supervisory feedback may become increasingly important even when an issue does not result in an MRA, MRIA, or formal enforcement action.
Read the full article:
This article was originally published on September 9, 2026, by Reuters Legal and Westlaw Today and is republished here with permission.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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