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Office of the Comptroller of the Currency of the United States

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Banking Associations Question Legality of Capital Requirements

by Starling Insights


Sep 25, 2023

Last week, a group of US banking trade associations — including the Bank Policy Institute, the American Bankers Association, the Financial Services Forum, the Institute of International Bankers, and others — published a letter to regulators. The trade associations claim that the US Federal Reserve, Office of the Comptroller of the Currency, and Federal Deposit Insurance Corporation violated the law by failing to publish the analysis and data supporting their capital requirements regime.

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What Does “Too Big To Manage” Mean For Banks?

by Starling Insights


Mar 06, 2023

In a recent American Banker op-ed, Keith Noreika, Executive Vice President at Patomak Global Partners and former US Acting Comptroller of the Currency, takes issue with recent arguments made by the current Acting Comptroller, Michael Hsu, that repeated misconduct issues may suggest some firms have grown "too big to manage."