On 29 February 2024, the Central Bank of Ireland (the "Central Bank") published a new Regulatory & Supervisory Outlook Report outlining the key trends and risks which the Central Bank has identified as moulding the financial...more
On February 23, 2024, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) published an order establishing supervisory authority over a small-loan consumer finance company, using a Dodd-Frank Act provision that...more
The CFPB has revised its internal supervisory appeals process for institutions seeking to appeal a compliance rating or an adverse material finding. The revisions became effective immediately upon publication in the Federal...more
On February 16, 2024, the Consumer Financial Protection Bureau (CFPB) announced what it heralded as a significant update to its Supervisory Appeals Process. The first of its kind since 2015, this revision introduced a...more
On February 16, 2024, the Consumer Financial Protection Bureau (CFPB) issued a procedural rule revising its supervisory appeals process for the first time since 2015. This Rule makes several important changes...more
On February 6, 2024, National Credit Union Administration (NCUA) Chairman Todd M. Harper spoke at a Brookings Institution event to outline his regulatory agenda and supervisory priorities for 2024. His prepared remarks...more
As discussed, in a recent letter, the Chairman of the National Credit Union Administration (NCUA) outlined the agency’s supervisory priorities for 2024. In this post, we delve deeper into the area of consumer protection...more
On January 23, the Chairman of the National Credit Union Administration (NCUA) released a letter outlining its supervisory priorities for the new year. While the organization acknowledged that the credit union system had...more
Rebecca Jackson, Executive Director, Authorisations, Regulatory Technology, and International Supervision at the Prudential Regulation Authority ("PRA") has written to international banks on the PRA’s thematic supervision...more
The Situation: In October 2023, the Office of the Comptroller of the Currency ("OCC"), Federal Reserve System, and Federal Deposit Insurance Corporation ("FDIC," and the three agencies collectively, "Agencies") finalized...more
On October 16 of last year, I reported that Eric Halperin, Enforcement Director of the CFPB, announced that the CFPB intended to substantially increase the number of enforcement staff by 50% and to create a 5th litigation...more
On November 3, the Financial Stability Oversight Council (FSOC) voted unanimously to finalize the procedures for designating a nonbank financial company for Federal Reserve supervision. FSOC’s Interpretive Guidance aims to...more
On October 4, 2023, the Office of the Superintendent of Financial Institutions (“OSFI”) released details of a new supervisory framework (“New Framework”) that will apply as of April 1, 2024 to federally-regulated financial...more
The Office of the Comptroller of the Currency’s (OCC) Committee on Bank Supervision (CBS) recently issued its annual Bank Supervision Operating Plan for FY 2024, which sets forth the OCC’s supervision priorities and...more
The FDIC has filed motion to dismiss the lawsuit filed in July 2023 in a Minnesota federal district against the FDIC and its Chairman seeking to invalidate the FDIC’s supervisory guidance on charging multiple non-sufficient...more
On July 6, 2023, the European Securities and Markets Authority (ESMA), in collaboration with National Competent Authorities (NCAs), launched the Common Supervisory Action (CSA) aimed at assessing the compliance of supervised...more
On August 8, 2023, the Board of Governors of the Federal Reserve System (FRB) issued two Supervision and Regulation Letters (“SR Letters”) that provide guidance on the agency’s supervision of novel activities and the process...more
Earlier this month, the Federal Reserve Board (FRB) released two supervision and regulation letters regarding the agency’s program to supervise “novel” banking activities....more
On Monday, Federal Deposit Insurance Corporation (“FDIC”) Chair Martin Gruenberg gave remarks to the Brookings Institution on “The Resolution of Large Regional Banks.” Chair Gruenberg did not say “I told you so” in his...more
In April 2022, the Basel Committee on Banking Supervision (the Basel Committee) began a review of “the core principles for effective banking supervision” (Core Principles or CP). Last month, the Basel Committee published...more
The Federal Reserve issued a Supervision and Regulation letter earlier this week to all state member banks (“SMBs”) regarding their involvement in activities involving stablecoins, taking an even more reticent position than...more
Earlier this week, the Federal Reserve issued a Supervision and Regulation Letter regarding the “Creation of Novel Activities Supervision Program” (SR 23-7). The letter informs all banking organizations subject to supervision...more
In April 2022, the Basel Committee on Banking Supervision (the Basel Committee) began a review of “the core principles for effective banking supervision” (Core Principles or CP). Last month, the Basel Committee published a...more
A complaint filed on July 20, 2023 in Minnesota federal court seeks declaratory and injunctive relief under the Administrative Procedures Act (APA) against defendants Federal Deposit Insurance Corporation (FDIC) and Chairman...more
On July 18, Office of the Comptroller of the Currency (OCC) Senior Deputy Comptroller for Large Bank Supervision Greg Coleman testified on OCC supervision of climate-related financial risks before the U.S. House of...more