FIS Center of Regulatory Intelligence The Future of Military Banking Risk, Information Security & Compliance (RISC) Solutions

Davis Polk Dodd-Frank Progress Report Six-Year Report July 19, 2016, 271rulemaking deadlines have passed. 210 (77.5%) met with finalized rules and rules proposed that would meet 29 (10.7%). Rules have not yet been proposed to meet 32 (11.8%) passed rulemaking requirements. Of the 390 total rulemaking requirements, 274 (70.3%) have been met with finalized rules and rules have been proposed that would meet 36 (9.2%) more. Rules not yet been proposed to meet 80 (20.5%) rulemaking requirements. I would encourage you all to signup for the Dodd Frank status reports provided by the law firm Davis Polk. It is a great source of information the status of the rulemakings under the Act. Here are some of the highlights: As of December 31, 2015, 271 rulemaking deadlines have passed. Of the 271 rulemaking requirements with deadlines that have passed, 204 (75.3%) have been met with finalized rules and rules have been proposed that would meet 34 (12.5%) more. Rules have not yet been proposed to meet 33 (12.2%) passed rulemaking requirements. Of the 390 total rulemaking requirements, 267 (68.46%) have been met with finalized rules and rules have been proposed that would meet 40 (10.26%) more. Rules have not yet been proposed to meet 83 (21.28%) rulemaking requirements.

U.S. Department of the Treasury White Paper “Opportunities and Challenges in Online Marketplace Lending” Prepared in response to Department of the Treasury’s Request for Information (“RFI”) “Public Input on Expanding Access to Credit through Online Marketplace Lending.” Themes 1. Use of Data and Modeling Techniques for Underwriting is an Innovation and a Risk There is Opportunity to Expand Access to Credit New Credit Models and Operations Remain Untested Small Business Borrowers Will Likely Require Enhanced Safeguards Greater Transparency Can Benefit Borrowers and Investors Secondary Market for Loans is Undeveloped Regulatory Clarity Can Benefit the Market Prepared in response to Department of the Treasury’s Request for Information (“RFI”) “Public Input on Expanding Access to Credit through Online Marketplace Lending.” Themes 1. Use of Data and Modeling Techniques for Underwriting is an Innovation and a Risk There is Opportunity to Expand Access to Credit New Credit Models and Operations Remain Untested Small Business Borrowers Will Likely Require Enhanced Safeguards Greater Transparency Can Benefit Borrowers and Investors Secondary Market for Loans is Undeveloped Regulatory Clarity Can Benefit the Market Recommendations 1.  Support more robust small business borrower protections and effective oversight; 2.  Ensure sound borrower experience and back-end operations; 3.  Promote a transparent marketplace for borrowers and investors; 4.  Expand access to credit through partnerships that ensure safe and affordable credit; 5.  Support the expansion of safe and affordable credit through access to government-held data; and 6.  Facilitate interagency coordination through the creation of a standing working group for online marketplace lending. Opportunities and Challenges in Online Marketplace Lending By: Daniel Cruz 5/10/2016 Page Content The U.S. Treasury Department today issued a white paper regarding its review of the online marketplace lending industry. The white paper titled, “Opportunities and Challenges in Online Marketplace Lending,” provides an overview of what the Treasury Department heard in response to its Request for Information, and it contains research on and recommendations for the industry. Treasury received approximately 100 responses to the RFI from online marketplace lenders, trade associations, consumer and small business advocates, academics, investors, and financial institutions

Office of the Comptroller of the Currency (OCC) White Paper “Supporting Responsible Innovation in the Federal Banking System: An OCC Perspective” OCC summarizes its research and discusses the principles guiding the development of its framework for understanding and evaluating innovation. Guiding Principles for the OCC’s Approach to Responsible Innovation 1. Support responsible innovation. 2. Foster an internal culture receptive to responsible innovation. 3. Leverage agency experience and expertise. 4. Encourage responsible innovation that provides fair access to financial services and fair treatment of consumers. 5. Further safe and sound operations through effective risk management. 6. Encourage banks of all sizes to integrate responsible innovation into their strategic planning. 7. Promote ongoing dialogue through formal outreach. 8. Collaborate with other regulators. Guiding Principles for the OCC’s Approach to Responsible Innovation 1. Support responsible innovation. 2. Foster an internal culture receptive to responsible innovation. 3. Leverage agency experience and expertise. 4. Encourage responsible innovation that provides fair access to financial services and fair treatment of consumers. 5. Further safe and sound operations through effective risk management. 6. Encourage banks of all sizes to integrate responsible innovation into their strategic planning. 7. Promote ongoing dialogue through formal outreach. 8. Collaborate with other regulators. Request for Comments 1. What challenges do community banks face with regard to emerging technology and financial innovation? 2. How can the OCC facilitate responsible innovation by institutions of all sizes? 3. How can the OCC enhance its process for monitoring and assessing innovation within the federal banking system? 4. How would establishing a centralized office of innovation within the OCC facilitate more open, timely, and ongoing dialogue regarding opportunities for responsible innovation? 5. How could the OCC provide guidance to nonbank innovators regarding its expectations for banks’ interactions and partnerships with such companies? 6. What additional tools and resources would help community bankers incorporate innovation into their strategic planning processes? 7. What additional guidance could support responsible innovation? How could the OCC revise existing guidance to promote responsible innovation? 8. What forms of outreach and information sharing venues are the most effective? 9. What should the OCC consider with respect to innovation? The Office of the Comptroller of the Currency (OCC) today published its perspective on responsible innovation in the federal banking system and solicited feedback on what more it could do to support innovation that better serves consumers, businesses, and communities. In Supporting Responsible Innovation in the Federal Banking System: An OCC Perspective, the agency summarizes its research and discusses the principles guiding the development of its framework for understanding and evaluating innovation. The OCC also seeks feedback on a series of questions about how to facilitate responsible innovation; how the agency can streamline its processes for evaluating innovative products, services and processes; how it can promote open dialogue with industry stakeholders; and, what additional tools and resources could assist national banks and federal savings associations with regard to innovation. “At the OCC, we are making certain that institutions with federal charters have a regulatory framework that is receptive to responsible innovation along with the supervision that supports it,” said Comptroller of the Currency Thomas J. Curry. “Innovation holds much promise. It can help meet the needs of the underserved and provide better financial tools for families. It can help institutions scale operations efficiently, and it can make business and consumer transactions faster and safer. Innovation is not free from risk, but when managed appropriately, risk should not impede progress.” Comments on the whitepaper should be sent to innovation@occ.treas.gov by May 31, 2016. The OCC will host a forum on responsible innovation on June 23, 2016, at Constitution Center in Washington, D.C. During the event, the agency will discuss comments received on the whitepaper and lead discussions regarding financial services innovation. The agency plans to release details on the agenda and how to register in April.

Banks have to continuously adapt in order to prosper, and we, as regulators, have to be knowledgeable enough to understand new technology and nimble enough to render timely decisions on matters requiring regulatory approval, as well as guidance about our supervisory expectations .  “ OCC has issued a white paper on Supporting Responsible Innovation in the Federal Banking System: An OCC Perspective The white paper calls for the OCC to: 1. Support responsible innovation. 2. Foster an internal culture receptive to responsible innovation. 3. Leverage agency experience and expertise. 4. Encourage responsible innovation that provides fair access to financial services and fair treatment of consumers. 5. Further safe and sound operations through effective risk management. 6. Encourage banks of all sizes to integrate responsible innovation into their strategic planning. 7. Promote ongoing dialogue through formal outreach. 8. Collaborate with other regulators. The agency is currently evaluating its statutory right to extend the same type of modified charter to fintech companies. Curry said it "probably" has the authority to offer a charter to "something that is a not deposit-taking entity." Thomas J. Curry Comptroller of the Currency American Banker Retail Banking Conference April 7, 2016

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