Community Banks

On September 11, 2026, the Agencies (FDIC, OCC, FRB, and NCUA) proposed interagency third-party risk management (TPRM) guidance (Proposed Guidance), which, if finalized, would replace the 2023 Interagency Guidance on Third-Party Relationships: Risk Management (2023 Guidance). Comments are due November 16, 2026. Separately, the FRB proposed TPRM guide for traditional community banking organizations (FRB Proposal), which is intended to serve as a companion document to the Proposed Guidance. It has the explicit goal of assisting “traditional community banking organizations” (TCBOs) (defined as...

We provide comprehensive legal counsel to banks ranging from community institutions to the largest national and regional banks, as well as specialized trust, wealth management, and employee benefits institutions. Our services span regulatory compliance and examination support, licensing and charter applications, M&A transactions, and public policy advocacy before Congress and federal banking regulators. Capital Analysis: We assess treatment of assets, instruments, and transactions under bank or GSE capital rules. Consumer Compliance: We assist clients with compliance matters on a variety of...