As we reported, Acting Comptroller of the Currency Brian Brooks has previewed the OCC’s plans to introduce another special purpose national bank charter that would give payment companies a nationwide servicing platform and...more
8/5/2020
/ Bank Holding Company Act ,
Banking Sector ,
Federal Bank Regulatory Agencies ,
Federal v State Law Application ,
Financial Services Industry ,
FinTech ,
Money Transmitter ,
National Bank Charters ,
OCC ,
Preemption ,
Special Purpose National Bank Charter
Recently, the federal banking regulators issued four new sets of examination procedures. The OCC issued two significant examination booklets on sampling methodologies and UDAP/UDAAP, and the federal banking regulators,...more
8/4/2020
/ Banking Regulators ,
Banking Sector ,
CARES Act ,
Comptroller ,
Coronavirus/COVID-19 ,
Dodd-Frank ,
Examination Procedures ,
Financial Institutions ,
FRB ,
FTC Act ,
UDAAP ,
UDAP
When the OCC issued its final Community Reinvestment Act (“CRA”) rule on May 20, 2020, the agency acted alone without waiting to achieve consensus with the FDIC, the agency with which the OCC had jointly issued its proposed...more
Over the past six weeks, opposition to the OCC’s Community Reinvestment Act (“CRA”) final rule has hardened on two fronts. The OCC’s decision to hurriedly issue the final rule on May 20, 2020 without achieving consensus with...more
On May 20, 2020, the OCC issued a final rule to “strengthen and modernize” its existing Community Reinvestment Act (“CRA”) regulations. This is the second in a series of five blog posts about the final rule....more
6/26/2020
/ Banks ,
Community Development ,
Community Reinvestment Act ,
Coronavirus/COVID-19 ,
FDIC ,
Federal Reserve ,
Final Rules ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Lending ,
Notice of Proposed Rulemaking (NOPR) ,
OCC ,
Performance Standards
On May 20, 2020, the OCC issued a final rule to “strengthen and modernize” its existing Community Reinvestment Act (“CRA”) regulations. According to the agency’s press release, the final rule is designed to increase...more
The FDIC has extended by 30 days the comment period on its proposed rule setting forth the conditions it would impose and the commitments it would require to approve a deposit insurance application from an industrial bank or...more
The OCC has issued a final rule revising its regulation implementing the Community Reinvestment Act (CRA). The final rule applies to national banks and federal savings associations....more
Effective April 24, 2020, the Federal Reserve amended Regulation D to remove the six-per-month limit on transfers or withdrawals from the definition of a “savings deposit.” The amendment is set forth in an interim final rule...more
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) includes the following key provisions that affect financial institutions and regulation of financial institutions...more
The FDIC has issued a proposed rule setting forth the conditions it would impose and the commitments it would require to approve a deposit insurance application from an industrial bank or industrial loan company...more
The OCC and FDIC announced yesterday that they have extended the 60-day comment period for their joint proposal to revise their regulations implementing the Community Reinvestment Act that was published in the Federal...more
The OCC and FDIC have issued a joint proposal to revise their regulations implementing the Community Reinvestment Act (CRA). Although the Federal Reserve, OCC and FDIC, are the primary CRA regulators, the Fed did not join...more
12/19/2019
/ Banks ,
Community Reinvestment Act ,
Consumer Financial Products ,
FDIC ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Financing ,
Joint Policy Statements ,
Lending ,
Low-Income Issues ,
Mortgages ,
OCC ,
Rulemaking Process
On October 10, 2019, the Board of Governors of the Federal Reserve System (Board), together with the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation, adopted a final rule to revise the...more
10/17/2019
/ Capital Requirements ,
Dodd-Frank ,
Economic Growth Regulatory Relief and Consumer Protection Act ,
FDIC ,
Federal Reserve ,
Final Rules ,
Financial Institutions ,
Financial Regulatory Reform ,
Foreign Banks ,
Liquidity ,
OCC ,
Prudential Standards ,
Risk-Based Approaches
On Tuesday, the FDIC released a Notice of Proposed Rulemaking (NPR) that outlines anticipated revisions to its regulations regarding interest rate restrictions that apply to less than well capitalized insured depository...more
The Federal Reserve Board has published in the Federal Register a notice of proposed rulemaking with request for comment on a proposal to simplify and increase transparency of its rules for determining control of a banking...more
The FDIC has issued an Advance Notice of Proposed Rulemaking (ANPR) seeking comment on its regulatory approach to brokered deposits and interest rate restrictions. ...more
At the Online Lending Policy Institute’s (OLPI) annual summit in Washington, D.C. earlier this week, the OCC’s recent decision to accept applications from non-depository financial technology firms for a special purpose...more
10/11/2018
/ Community Reinvestment Act ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Disclosure Requirements ,
Financial Services Industry ,
FinTech ,
Innovation ,
Online Marketplace Lending ,
Regulatory Oversight ,
Regulatory Standards ,
Sandbox ,
Special Purpose National Bank Charter
Last Wednesday the Federal Reserve published approved final amendments to Regulation CC (Availability of Funds and Collections of Checks) which update the liability provisions of Reg. CC to address the nearly-complete...more
On September 12th, the Conference of State Bank Supervisors (CSBS) announced that it would again pursue litigation in opposition to the OCC’s recent decision to accept applications from non-depository financial technology...more
In a recent interview (her first since being sworn in as Chair of the Federal Deposit Insurance Corporation), Jelena McWilliams provided insight into the FDIC’s likely regulatory agenda....more
8/14/2018
/ Capital Requirements ,
Community Reinvestment Act ,
Consumer Financial Products ,
Deposit Insurance ,
FDIC ,
Global Systemically Important Banks (G-SIBs) ,
Loans ,
National Bank Charters ,
Regulatory Agenda ,
Regulatory Burden ,
Regulatory Oversight ,
Volcker Rule
The Office of the Comptroller of the Currency’s (OCC) announcement this week that it will begin accepting applications for special purpose national bank (SPNB) charters from financial technology (Fintech) companies represents...more
8/3/2018
/ Capital Requirements ,
FDIA ,
Financial Services Industry ,
FinTech ,
Fintech Charter ,
National Bank Charters ,
OCC ,
Policy Statement ,
Preemption ,
Regulatory Requirements ,
Special Purpose National Bank Charter
Last week, Representative Blaine Luetkemeyer, Chair of the House Financial Services Committee’s Subcommittee on Financial Institutions and Consumer Credit, and Representative Scott Tipton sent a letter to Jelena McWilliams,...more
The U.S. House of Representatives on Tuesday passed S.2155, the Economic Growth, Regulatory Relief, and Consumer Protection Act (the Act), by a vote of 258 to 159. ...more
The U.S. Senate on March 14 passed S.2155, the Economic Growth, Regulatory Relief, and Consumer Protection Act (the Act), by a vote of 67 to 31. Although the Act would not make the sweeping changes to the Dodd-Frank Act found...more
3/16/2018
/ Appraisal ,
Banking Sector ,
Consumer Financial Protection Bureau (CFPB) ,
Dodd-Frank ,
Financial Institutions ,
Financial Regulatory Reform ,
FIRREA ,
FSOC ,
HMDA ,
Legislative Agendas ,
Mortgages ,
Online Marketplace Lending ,
Orderly Liquidation Authority ,
PACE ,
Proposed Legislation ,
Regulatory Oversight ,
Student Loans ,
TILA-RESPA Integrated Disclosure Rule (TRID) ,
Truth in Lending Act (TILA)