A federal judge recently dismissed a complaint brought by the New York Bankers Association (NYBA) seeking to invalidate the New York City Responsible Banking Act (the Responsible Banking Act). In New York Bankers Ass’n Inc....more
According to the final rule recently issued by the Office of the Comptroller of the Currency (OCC) formalizing the agency’s “heightened expectations” supervisory regime, the largest U.S. federally chartered depository...more
The Uniform Law Commission (ULC), a non-partisan organization committed to drafting uniform state laws, has authorized the formation of a committee to study the need for and feasibility of state legislation to address the...more
June 2014 saw the publication of some interagency FAQs on the Volcker Rule (the Rule) and interim procedures from the Office of the Comptroller of the Currency (OCC) for its examiners to use in assessing progress by national...more
"Operation Choke Point," the coordinated multiagency federal effort to choke off banking services to alleged fraudsters (according to its defenders) or politically unpopular industries (according to its detractors), has come...more
6/13/2014
/ ACH Payments ,
Administrative Procedure Act ,
Banks ,
Choke Point ,
Community Financial Services Association ,
Consumer Financial Protection Bureau (CFPB) ,
Department of Justice (DOJ) ,
FDIC ,
Fraud ,
OCC ,
Payday Loans
This Tuesday, April 8, the House Financial Services Committee will hold a hearing entitled “Who’s in Your Wallet: Examining How Washington Red Tape Impairs Economic Freedom.”
...more
The Office of the Comptroller of the Currency (OCC) last week released proposed amendments to its Part 30 regulations, which reflect the agency’s “heightened expectations” for large banks. That release, styled as an “Interim...more
It took almost 3½ years before it finally hatched. And it was big—very big—enormous, in fact. No, it’s not Godzilla. It’s the Volcker Rule.
More than two years after the Notice of Proposed Rulemaking, a final rule...more
The Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) have carried out their threats in their proposed guidance to kill deposit advance loans. On November 21, 2013, the two...more
The Office of the Comptroller of the Currency (OCC) recently issued a new Bulletin 2013-29 containing substantially more onerous risk management guidance for third-party business relationships (3PRs) of national banks and...more
The Office of the Comptroller of the Currency (OCC) recently issued guidance on what it looks for when requiring national banks and federal thrifts in enforcement orders to engage third-party consultants (3PCs). Bulletin...more
The Office of the Comptroller of the Currency (OCC) has made clear that all national banks and federal savings associations can expect increased scrutiny of their debt sales practices, as well as supervisory guidance...more
The Office of the Comptroller of the Currency (OCC) recently updated its guidance on procedures for internal appeals of supervisory decisions at various levels. The subject matter deals solely with internal appeal procedures...more