Anastasia V. Peterson

Feb 26, 2024 | lexology.com | Jarryd E. Anderson |Scott A. Barshay |Jessica Carey |Brad S. Karp |Robert Kindler |Anastasia V. Peterson | +3 more

I. Executive SummaryOn January 29, 2024, the Office of the Comptroller of the Currency (“OCC”) issued a notice of proposed rulemaking (the “NPR”)[1] to update its current rules for business combinations involving national banks and federal savings associations, including a policy statement that describes the standards for the OCC’s review of business combinations under the Bank Merger Act (“BMA”) (the “Policy Statement”).

Jan 29, 2024 | lexology.com | Jarryd E. Anderson |H. Christopher Boehning |Susanna M. Buergel |Jessica Carey |Michael E. Gertzman |Roberto González | +3 more

Introduction On January 22, 2024, the New York State Department of Financial Services (“NYDFS”) issued final Guidance (the “Guidance”) for most institutions holding a license from the NYDFS[1] (“Covered Institutions”) setting out NYDFS’s expectation that Covered Institutions engage in rigorous character and fitness assessments of directors, senior officers and managers, both at onboarding and on an ongoing basis.[2] The Guidance reflects an ongoing effort by policymakers and regulators to...