Tag: OCC

  • Material Loss Reviews: Does responsibility = liability?

    I asked in my previous post whether or not the regulators should share any of the blame when institutions fail, and if so, should they shoulder any of the liability?  The thought occurred to me as I was reviewing some recent Material Loss Reviews. A Material Loss Review (MLR)  is a post-mortum written by the…

  • Dodd-Frank and agency consolidation

    Although the specific requirements and burdens of the almost 250 regulations and more than 2000 pages in the Dodd-Frank Act are yet to…

  • FDIC can now step in regardless of primary regulator (part 2)

    Further to the previous post, the memorandum requires the FDIC opinion to prevail in the event that an institutions’ PFR (primary federal regulator) CAMELS rating differs from the FDIC: If the FDIC’s CAMELS ratings for an institution differ from a PFR’s assigned ratings, the FDIC is required to provide the PFR with an explanation of…

  • FDIC can now step in regardless of primary regulator (part 1)

    According to a memorandum of understanding just signed by all the primary federal regulators (FDIC, OTS, OCC and Fed), the FDIC now has the authority to step in whenever they feel the DIF (deposit insurance fund) is in jeopardy. Although this is primarily targeted at larger (>$10b) institutions, it also applies to smaller (<$10b) institutions…