On October 25, 2016, OCC Comptroller of the Currency Thomas J. Curry delivered remarks to a group of bank regulators at the tenth annual FDIC Accounting and Auditing Conference.  The remarks, addressing the importance of interagency collaboration, provide insight into how Comptroller Curry views the OCC’s relations with the other banking agencies.

In his remarks, Comptroller Curry provided examples of exemplary interagency collaboration, including the Federal Financial Institutions Examination Council’s (“FFIEC”) work on BSA/AML examination manual and cybersecurity assessment tool, as well as the collaboration fostered by the Financial Stability Oversight Committee (“FSOC”). Comptroller Curry also noted the importance of interagency collaboration in helping banks and thrifts, particularly community banks, thrive, referencing the OCC’s 2015 paper that encourages community banks to work together.

Comptroller Curry told the bank regulators in the audience that he was “particularly proud” of the OCC’s coordination with the CFPB, emphasizing the “Coordination Principles” between the agencies announced earlier this year. Comptroller Curry described the agencies as having “clearly distinct jurisdictions” and said that, as the agencies’ relationship has matured since the CFPB’s establishment, “viewing our work competitively at any level is counterproductive.”

Photo of Mike Nonaka Mike Nonaka

Michael Nonaka is co-chair of the Financial Services Group and advises banks, financial services providers, fintech companies, and commercial companies on a broad range of compliance, enforcement, transactional, and legislative matters.

He specializes in providing advice relating to federal and state licensing and…

Michael Nonaka is co-chair of the Financial Services Group and advises banks, financial services providers, fintech companies, and commercial companies on a broad range of compliance, enforcement, transactional, and legislative matters.

He specializes in providing advice relating to federal and state licensing and applications matters for banks and other financial institutions, the development of partnerships and platforms to provide innovative financial products and services, and a broad range of compliance areas such as anti-money laundering, financial privacy, cybersecurity, and consumer protection. He also works closely with banks and their directors and senior leadership teams on sensitive supervisory and strategic matters.

Mike plays an active role in the firm’s Fintech Initiative and works with a number of banks, lending companies, money transmitters, payments firms, technology companies, and service providers on innovative technologies such as bitcoin and other cryptocurrencies, blockchain, big data, cloud computing, same day payments, and online lending. He has assisted numerous banks and fintech companies with the launch of innovative deposit and loan products, technology services, and cryptocurrency-related products and services.

Mike has advised a number of clients on compliance with TILA, ECOA, TISA, HMDA, FCRA, EFTA, GLBA, FDCPA, CRA, BSA, USA PATRIOT Act, FTC Act, Reg. K, Reg. O, Reg. W, Reg. Y, state money transmitter laws, state licensed lender laws, state unclaimed property laws, state prepaid access laws, and other federal and state laws and regulations.