The Consumer Bankers Association (CBA), a trade group of retail financial institutions, recently sent a letter to the Consumer Financial Protection Bureau (CFPB) director, requesting increased supervision of financial...more
On August 27, the Board of Governors of the Federal Reserve, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the “Agencies”) issued “Conducting Due Diligence on...more
As our colleagues from the Consumer Financial Services Group reported on August 11, the Federal Financial Institutions Examination Council (FFIEC) issued guidance titled “Authentication and Access to Financial Institution...more
In the future, most de novo banks in the United States will be formed by existing payments and nonbank fintech companies that provide financial services, or groups of players in those industries that want to form a payments...more
The Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), and the Department of the Treasury Office of the Comptroller of the Currency (OCC) have published proposed...more
On June 24, the House of Representatives, like the Senate on May 11, voted to overturn the Office of the Comptroller of Currency’s (OCC) “True Lender Rule” that was finalized in October 2020. The Senate initiated the process...more
There has been recent turmoil in the U.S. stock markets over the past few weeks as the country starts to take steps toward reopening as a result of the pandemic. However, financial institution stocks have been buoyed by...more
Twice a year — once in the spring and then again at the end of the year — the Board of Governors of the Federal Reserve System (Federal Reserve) publishes a report on banking conditions in the United States. Typically, the...more
The Department of Financial Protection and Innovation (DFPI) of California entered a settlement agreement with Chime Financial, Inc. (Chime), a neobank company that is not licensed to operate as a bank or otherwise exempt...more
On April 9, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies), in consultation with the Financial...more
The trend of fintech companies seeking or acquiring U.S. banking licenses continues to build momentum, furthering the convergence of fintech and banking. More fintech companies are applying and being approved for banking...more
The growing role of technology in banking cannot be overstated. Financial technology is reshaping the retail banking industry in real time — changing the way banks receive deposits, lend money, and invest. At the same time, a...more
Prior to the COVID-19 pandemic, many combined factors pushed the banking industry toward consolidation, greater efficiency, and in many instances, smaller branch footprints. When COVID-19 forced banks to close branch lobbies...more
Who Needs to Know -
Lenders and borrowers involved in financing transactions, any companies using LIBOR swap or derivative transactions. ...more
In a final act of his tenure, Brian Brooks, the acting Comptroller of the Currency (OCC) on January 14 finalized a rule to ensure “fair access to banking services provided by large national banks, federal savings...more
Troutman Pepper has produced a series of podcasts on legal and business issues faced by companies during the COVID-19 pandemic.
This episode features Troutman Pepper Financial Institutions lawyers Zayne Tweed (moderator) and...more
On December 15, the Federal Deposit Insurance Corporation (FDIC) issued a final rule (Final Rule) establishing a new framework for analyzing whether bank deposits obtained through third-party arrangements are brokered...more
On November 20, the Office of the Comptroller of Currency (OCC) proposed a rule aimed at ensuring fair access to bank services, capital, and credit. Citing pushes from across the political spectrum to “de-bank” industries...more
On October 27, the Office of the Comptroller of the Currency (OCC) issued its final rule on how to determine when a national bank or federal savings association (referred to collectively as a national bank) is the “true...more
On September 15, the Conference of State Bank Supervisors (CSBS) announced that money transmitters operating in 40 or more states will be able to take advantage of a new, comprehensive exam designed to satisfy all state money...more
In the first case decided on the issue of whether Madden v. Midland Funding, LLC is applicable to a credit card securitization, the United States District Court for the Western District of New York, on September 21, 2020,...more
On September 15, the Conference of State Bank Supervisors (CSBS) announced that money transmitters operating in 40 or more states will be able to take advantage of a new, comprehensive exam designed to satisfy all state money...more
On September 11, the U.S. Securities and Exchange Commission (SEC) announced the adoption of rules to update and expand the disclosures that banking registrants provide to investors. The new rule has been long in the making....more