Archives for OCC

Letter to the Fed, FDIC, and OCC regarding Enhanced Cyber Risk Management Standards (1/18/17)

Date: January 18, 2017

Issue: Cyber

To: Federal Reserve; Federal Deposit Insurance Corporation; and Office of the Comptroller of the Currency

Filing Type: Comment Letter

Description: This letter is the Chamber's response to the Agencies' request for public comment regarding their joint advance notice of proposed rulemaking on “Enhanced Cyber Risk Management Standards.” American financial institutions and related entities are well aware of the substantial risks that cyber threats pose to the financial system. To mitigate these risks, they have invested heavily in developing cyber risk management programs, supported by substantial technological and personnel investments. The Agencies should not attempt to impose prescriptive requirements, but support industry efforts to enhance financial sector cybersecurity. The Chamber is urging policymakers to help agencies harmonize existing regulations with the NIST Cybersecurity Framework.

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Proposed Guidance on Deposit Advance Products,” and “Proposed Guidance on Deposit Advance Products; Withdrawal of Proposed Guidance on Deposit-Related Consumer Credit Products

Date: May 30, 2013

Issue: Corporate Governance

To: Federal Deposit Insurance Corporation and Office of the Comptroller of the Currency

Filing Type: Regulatory

Description: CCMC submitted a letter to the FDIC and OCC requesting that the agencies withdraw the new proposed guidance relating to deposit advance products. We believe that this guidance circumvents the legal requirements of promulgating a consumer protection rule exemplifying our concerns about regulators using the supervision process to write “rules”.

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