Articles

Q1’2024 Newsletter

Key Regulatory Updates Operational Resilience Acting Comptroller of the Currency, Michael J. Hsu, on March 14, 2024, addressed the Institute of International Bankers at their annual conference in Washington, DC on the topic of operational resilience[1]. Operating risks and the ability to recover from unexpected external events or...

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Regulatory Focus on CRE Loan Concentration Risk

January 2024 During recent times, banking regulators have increased their focus on the concentration of loans in the commercial real estate sector. This is due to the fact a high concentration of loans in a specific sector, such as Commercial Real Estate (“CRE”), can pose significant risks to...

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Common Themes in Enforcement Actions

October 2023 An analysis of the formal Enforcement Actions issued by the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC) and some State Banking Regulators during 2023 reveal some common themes, some of which were seen even in prior years, e.g., BSA/AML/OFAC...

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Reevaluating Operational Risk Management

July 2023 Last month, in June 2023, we published an article entitled, “Risk Management- Managing Third-Party Risks,” which focused on the final regulatory guidance relating to managing the risks related to third-party relationships that was issued then. However, considering that in addition to third-party risks, operational activities which...

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