Becoming or owning an industrial loan company (or ILC)—the elusive "nonbank bank" option, as Congress coined the term in 1987— still has an allure for financial services providers that want to (1) lend on a national scale...more
It is no secret that the Federal Reserve, the FDIC, and the OCC have zeroed in on banks' use of third parties for products, services, and other operations, the risks those arrangements may pose, and banks' responsibility to...more
5/14/2024
/ Banking Regulators ,
Banking Sector ,
Banks ,
Community Banks ,
Enforcement ,
Enforcement Actions ,
FDIC ,
Federal Reserve ,
Final Guidance ,
Financial Institutions ,
Joint Policy Statements ,
New Guidance ,
Nonbank Firms ,
OCC ,
Regulatory Oversight ,
Risk Management ,
Third-Party ,
Third-Party Risk
In January 2024, one of the largest U.S. non-bank merchant acquirers announced that it is pursuing a special-purpose bank charter developed by Georgia. Although the “merchant acquirer limited purpose bank” (MALPB) has been a...more
Since the 2023 spring bank failures, the federal banking agencies have tinkered with significant bank regulations and guidance—ranging from capital, bail-in measures, and resolution planning to climate-risk stress testing,...more