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Karen Solomon advises clients on a broad range of financial services regulatory matters. Ms. Solomon’s extensive experience working in agencies that supervise national banks and Federal savings associations enables her to offer an informed, practical approach to addressing regulatory issues.
Before joining Covington, Ms. Solomon served as the Acting Senior Deputy Comptroller and Chief Counsel at the Office of the Comptroller of the Currency (OCC). In that role and in her prior role as Deputy Chief Counsel, Ms. Solomon’s work included developing and drafting regulations and advising on issues involving bank powers, structure, compliance, and preemption as well as on licensing, legislative, and litigation-related matters. She had a leadership role in key OCC initiatives, including the agency’s implementation of the Volcker rule, recent fintech chartering initiative, and federal preemption efforts. She also worked extensively with other Federal agencies on joint or collaborative regulatory projects. Ms. Solomon joined the OCC in 1995. Before that, she was Deputy Chief Counsel at the Office of Thrift Supervision (OTS) and, earlier, held senior positions at the OTS’s predecessor agency, the Federal Home Loan Bank Board.
Previous Experience
- Office of the Comptroller of the Currency, Acting Senior Deputy Comptroller and Chief Counsel; Deputy Chief Counsel; Director, Legislative and Regulatory Activities Division
- Office of Thrift Supervision, Deputy Chief Counsel
- Federal Home Loan Bank Board, Director, Regulations and Legislation
July 21, 2020, Covington Alert
On July 20, 2020, the Office of the Comptroller of the Currency (OCC) released a proposed rule intended to establish a bright-line test to identify the “true lender” in lending partnerships between national banks and federal savings associations, and third parties. Uncertainty in this area has caused confusion because the identity of the lender determines which ...
OCC Proposes Rule To Settle 'True Lender' Question
July 20, 2020, Law360
Karen Solomon is quoted in Law360 regarding the Office of the Comptroller of the Currency’s proposed rule to clarify the “true lender” question. Ms. Solomon says, “The OCC's proposal is a clear and very straightforward way of resolving the true lender issue.” She adds the OCC makes clear in its notice that if a bank is designated the loan originator, it will ...
June 29, 2020, Covington Alert
On June 25, 2020, five federal financial regulators jointly issued a final rule that modifies existing regulations implementing the Volcker Rule’s general prohibition on banking entities investing in, sponsoring, or having certain relationships with hedge funds or private equity funds (collectively, “covered funds”). The substance of the final rule is largely ...
June 22, 2020, Covington Alert
In response to the COVID-19 pandemic, state and local lawmakers have implemented measures requiring financial institutions to provide relief to consumers, such as forbearance on loan payments or waiving fees. The OCC has released a bulletin reminding stakeholders that federally-chartered institutions generally are governed primarily by uniform federal standards ...
OCC Initiates Push To Reassess Banking Innovation Rules
June 4, 2020, Law360
Karen Solomon spoke with Law360 about the Office of the Comptroller of the Currency’s push to speed up the digital transformation in banking. Ms. Solomon says, “Acting Comptroller Brooks has been a strong advocate for the use of technology in banking. This ANPR clearly places technology and innovation at the top of his agenda for the OCC.” The agency’s request ...
June 3, 2020, Covington Alert
On May 27, 2020, the Federal Reserve Bank of Boston ("FRBB") posted a number of documents that provide important additional details about its Main Street Lending Program ("MSLP"), including updated FAQs, new required agreements and forms, and new lender and borrower guides. The following summary highlights key FAQ changes and summarizes each of the new MSLP ...
May 26, 2020, Covington Alert
On May 20, 2020, the Office of the Comptroller of the Currency (the “OCC”) issued a final rule overhauling its regulations implementing the Community Reinvestment Act (the “CRA”). The CRA, enacted in 1977, incentivizes banks to meet the credit needs of their entire communities, including low- and moderate-income (“LMI”) neighborhoods. The final rule makes the ...
May 22, 2020, Covington Alert
Today, May 22, the Consumer Financial Protection Bureau (“CFPB”) issued an important no-action letter template in response to an application by the Bank Policy Institute (“BPI”), which could serve as the basis for no-action letter applications by BPI members and other deposit-taking institutions that wish to offer a standardized, small-dollar credit product as ...
May 21, 2020, Covington Alert
On May 20, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency (collectively, the “agencies”) issued interagency principles (the “Lending Principles”) to encourage supervised banks, savings associations, and credit unions ...
May 4, 2020, Covington Alert
On May 4, 2020, the Federal Reserve Bank of New York (the “FRBNY”) released an updated series of Frequently Asked Questions (“FAQs”) regarding two of the Federal Reserve’s liquidity facilities established to provide financial assistance to businesses impacted by the COVID-19 pandemic: the Primary Market Corporate Credit Facility (“PMCCF”) and the Secondary ...
May 1, 2020, Covington Alert
Yesterday, April 30, 2020, the Board of Governors of the Federal Reserve System announced important changes to the Main Street Lending Program (the “Program”) that it had introduced on April 9, 2020. The changes reflect further information and clarification with respect to the terms and conditions of the Program and address, at least in part, feedback that the ...
May 1, 2020, American Banker
Karen Solomon is quoted in the American Banker regarding the potential emergence of fully remote bank exams. Ms. Solomon says, “The agencies can’t just pick up where the old schedule left off by the time the pandemic winds down. It’s going to take some time to catch up. This is uncharted territory."
April 23, 2020, Covington Alert
As the Paycheck Protection Program (“PPP”) is about to re-open following passage of a bill that will provide additional $310 billion in funds to the program (including funds reserved for loans by certain small and mid-sized lenders), the rules of the Small Business Administration (“SBA”) that prohibit or restrict loans to the small business ventures of bank ...
April 9, 2020, Covington Alert
Today, the Board of Governors of the Federal Reserve announced the creation of four new liquidity facilities and the expansion of three previously announced liquidity facilities to provide credit to borrowers impacted by the COVID-19 pandemic. Whereas the previously announced programs primarily targeted certain financial markets and their participants (such as ...
March 25, 2020, Covington Alert
The U.S. Congress appears close to finalizing the scale and scope of stimulus legislation to address the economic crisis caused by the COVID-19 pandemic. Although its final shape remains uncertain, it is highly likely to provide for one or more lending programs, loan guaranty programs, and other financing programs administered by the federal government to direct ...
March 24, 2020, Covington Alert
The past several days have seen a flurry of activity among the federal banking agencies to take both proactive and responsive steps to address the impacts of COVID-19 on the banking industry and support continued lending to the real economy as the crisis unfolds. In case you missed it, here’s a quick recap of recent federal banking agency actions, along with ...
March 24, 2020, Covington Alert
On March 23, the Board of Governors of the Federal Reserve System (the “FRB”) announced the latest in a series of extraordinary actions intended to help mitigate the impacts of the COVID-19 pandemic on the U.S. economy. Unlike the measures announced last week – which mostly involved re-establishing emergency programs that were used during the 2008–09 financial ...
March 19, 2020, Covington Alert
Yesterday, on March 18, 2020, the Board of Governors of the Federal Reserve System (“Board”) announced the creation of a Money Market Mutual Fund Liquidity Facility (“MMLF”) to provide liquidity support to money market mutual funds (“MMMFs”) by facilitating their sale of certain assets in order to meet redemption requests. Under the MMLF, the Federal Reserve ...
The FDIC's Proposed Rule for Industrial Banks and Industrial Loan Companies: Five Things to Know
March 19, 2020, Covington Alert
On March 17, 2020, the Federal Deposit Insurance Corporation issued a notice of proposed rulemaking that would codify the FDIC’s existing supervisory processes and policies that apply to industrial banks and industrial loan companies (collectively, “ILCs”) and their parent companies. The FDIC issued the Proposal to formalize its ILC supervisory framework and to ...
March 18, 2020, Covington Alert
Yesterday, on March 17, 2020, the Board of Governors of the Federal Reserve System (“FRB”) announced the creation of a Primary Dealer Credit Facility (“PDCF”) to provide a liquidity backstop to primary dealers of the Federal Reserve Bank of New York (“FRBNY”), which include the nation’s largest broker-dealers. The PDCF will provide short-term loans to primary ...
March 17, 2020, Covington Alert
Today, on March 17, 2020, the Federal Reserve provided a backstop of commercial paper ("CP") in the form of a Commercial Paper Funding Facility (“CPFF”) that establishes a special purpose vehicle (“SPV”) to acquire eligible CP directly from eligible issuers. The CPFF will provide liquidity to CP issuers that may otherwise face issues rolling over their CP in ...
Federal Reserve Takes Extraordinary Actions Supporting Financial Markets to Mitigate COVID-19 Impact
March 16, 2020, Covington Alert
Yesterday, on Sunday, March 15, 2020, in response to the COVID-19 pandemic’s impact on U.S. and global economic activity, the Federal Reserve’s Federal Open Market Committee (“FOMC”) cut the target range of the federal funds rate to 0 to 1/4 percent until such time as the FOMC is “confident that the economy has weathered recent events and is on track to achieve ...
February 4, 2020, Covington Alert
On January 30, 2020, five federal financial regulators jointly issued a proposed rule that would modify existing regulations implementing the Volcker Rule’s general prohibition on banking entities investing in, sponsoring, or having certain relationships with hedge funds or private equity funds (collectively, “covered funds”). The proposal, which follows a 2019 ...
January 31, 2020, Covington Alert
On January 30, 2020, the Board of Governors of the Federal Reserve System (“Board”) unanimously approved a final rule that establishes a comprehensive framework for determining whether a company (“investor”) controls another company (“investee”) for purposes of the Bank Holding Company Act (“BHCA”) and Home Owners’ Loan Act (“HOLA”), and clarifies certain ...
January 2020, The Banking Law Journal
December 16, 2019, Covington Alert
On December 12, 2019, the Office of the Comptroller of the Currency (“OCC”) and Federal Deposit Insurance Corporation (“FDIC”) released a notice of proposed rulemaking to overhaul the agencies’ regulatory framework for evaluating banks’ Community Reinvestment Act (“CRA”) performance. The proposal follows a 2018 advance notice of proposed rulemaking by the OCC, ...
Bank Regulators' Madden Fixes May Not Be Quick Ones
November 22, 2019, Law360
Karen Solomon is quoted in Law360 regarding the Office of the Comptroller of the Currency and Federal Deposit Insurance Corporation’s draft regulations to curb uncertainty in the consumer credit and securitization markets in the wake of the controversial Madden v. Midland Funding decision. This court decision upset long-standing industry expectations that the ...
November 20, 2019, Covington Alert
On November 18 and 19, 2019, the Office of the Comptroller of the Currency (OCC) and Federal Deposit Insurance Corporation (FDIC) provided long-awaited regulatory affirmation that a bank loan’s rate of interest retains its non-usurious character when acquired by a third-party. The agencies each issued proposed rules that seek, as the OCC put it, to “codify what ...
November 19, 2019, Covington Alert
In a recent Interpretive Letter, the Office of the Comptroller of the Currency (OCC) addressed a proposal from an OCC-regulated bank to automate its process for filing suspicious activity reports (SARs) under the Bank Secrecy Act (BSA).
October 18, 2019, Covington Alert
On October 10, 2019, the Board of Governors of the Federal Reserve System (“Board”) released two final rules to tailor and modify the applicability of enhanced prudential standards for bank holding companies (“BHCs”), savings and loan holding companies that are not substantially engaged in insurance underwriting or commercial activities (“Covered SLHCs”), ...
October 17, 2019, Covington Alert
On September 10, 2019, the Consumer Financial Protection Bureau issued a No-Action Letter Policy, along with a Compliance Assistance Sandbox Policy and Trial Disclosure Program Policy, to promote innovation and facilitate compliance in consumer financial services. Covington & Burling LLP is pleased to provide this Model No-Action Letter Application as a ...
August 27, 2019, Covington Alert
On August 20, 2019, the Board of Directors of the Federal Deposit Insurance Corporation (the “FDIC”) approved a final rule (the “final rule”)1 that will significantly revise existing regulations implementing the Volcker Rule – a statutory provision that generally prohibits banking entities from engaging in proprietary trading or taking an ownership interest in, ...
Prominent Financial Services Lawyer Joining Covington
July 1, 2019
WASHINGTON—Jeremy Newell has joined Covington's Financial Services Group as a partner in Washington. Mr. Newell's arrival follows the recent addition of Karen Solomon, who joined Covington after serving as the acting Chief Counsel of the Office of the Comptroller of the Currency. Mr. Newell was formerly Executive Vice President, General Counsel & Chief ...
States' Model Payments Law May Ease Entry For Fintechs
June 14, 2019, Law360
Karen Solomon is quoted in Law360 regarding the Conference of State Banking Supervisors’ push to knock down barriers to entry for small fintech companies. Ms. Solomon says, “CSBS, for example, has released a series of recommendations aimed at streamlining and simplifying the multiple state requirements that apply when nonbank firms conduct business across state ...
May 8, 2019, Covington Alert
May 3, 2019, Covington Alert
On April 29, 2019, the Office of the Comptroller of the Currency (OCC) issued an Advance Notice of Proposed Rulemaking (ANPR) seeking comment on expansion of the term “fiduciary capacity” in part 9 and part 150 of the OCC’s regulations to include certain trust-related roles authorized under state law, potentially including roles that do not involve investment ...
May 2019, The Banking Law Journal
April 18, 2019, Covington Alert
On April 8, 2019, the Board of Governors of the Federal Reserve System (the “Board”) approved a notice of proposed rulemaking (the “Resolution Plan Proposal” or the “Proposal”), issued jointly with the Federal Deposit Insurance Corporation (the “FDIC,” and together with the Board, the “Agencies”), that would revise the Agencies’ jointly issued resolution ...
April 17, 2019, Covington Alert
On April 8, 2019, the Board of Governors of the Federal Reserve System (“Board”) released two proposals to tailor and modify the applicability of enhanced prudential standards for foreign banking organizations (“FBOs”) and their U.S. intermediate holding companies (“IHCs”).
March 13, 2019, Covington Alert
On March 6, 2019, the Financial Stability Oversight Council (“FSOC”) voted unanimously to issue proposed interpretive guidance (“Proposed Guidance”) that would significantly change its approach to designating nonbank financial companies that pose a risk to the financial stability of the United States (“nonbank SIFIs”) for supervision and prudential regulation by ...
Covington Snags OCC Deputy Comptroller And Chief Counsel
January 14, 2019, Law360
Law360 covered Karen Solomon’s move to Covington from The Office of the Comptroller of the Currency. Ms Solomon, who served as the OCC’s acting senior deputy comptroller and chief, counsel, told Law360 that she’s happy to be working in the private sector after an entire career spent in the government. “It seemed like the right time to try something different,” ...
January 9, 2019
WASHINGTON—Karen Solomon has joined Covington's Financial Services Group in Washington. Before joining Covington, Ms. Solomon served as the Acting Senior Deputy Comptroller and Chief Counsel at the Office of the Comptroller of the Currency (OCC). In that role and in her prior role as Deputy Chief Counsel, Ms. Solomon’s work included developing and drafting ...