Navigating Regulatory Waters: Recent Enforcement Actions in BaaS — Payments Pros – The Payments Law Podcast
Consumer Finance Monitor Podcast Episode: Have State-Chartered, FDIC-Insured Banks Finally Achieved Interstate Usury Parity with National Banks?
Consumer Finance Monitor Podcast Episode: Regulators Escalate Focus on the Risks of Bank Relationships with Fintechs and Other Third Parties
2024 State Legislative Review: Key Payment Laws and Their Impacts — Payments Pros – The Payments Law Podcast
First Republic Executives Fail in Attempt to Recover Nonqualified Deferred Compensation Plan Assets
The Future of Bank-Fintech Partnerships and Banking as a Service — The Consumer Finance Podcast
In That Case: Cantero v. Bank of America
Navigating Bank-Fintech Partnerships: Avoiding Common Pitfalls — The Consumer Finance Podcast
Revisiting Financial Institution Incentive Compensation Rules Under Dodd-Frank — The Consumer Finance Podcast
Redlining Complications Caused by Implementation of 2020 Census Tracts
U.S. District Court Addresses Federal Preemption for State Credit Reporting Laws
How to estimate how your performance will look under the new CRA
Instant Decline, Instant Relief? Unpacking the CFPB's Proposed Rule on NSF Fees — Payments Pros: The Payments Law Podcast
Fintech Focus Podcast | Are Regulators Dictating Fintech Deal Terms?
The Coming Perfect Storm
2023 Payments Year in Review: CFPB and FTC Regulatory Trends — Payments Pros – The Payments Law Podcast
Year in Review and a Look Ahead: Fintech Developments — The Consumer Finance Podcast
The CFPB Targets Data Brokers with Latest Proposed Rule
State Laws on Screening and Federal Preemption – Where Are We Now and Where Are We Heading? — FCRA Focus Podcast
Redefining Banking: A Conversation on the CFPB's Proposed 1033 Rule — Payments Pros: The Payments Law Podcast
The Office of the Comptroller of the Currency’s Committee on Bank Supervision sets the agency’s supervision objectives and priorities. On October 1, the Committee released the OCC’s Bank Supervision Operating Plan (the...more
Volume 4, Issue 2, 2024 Welcome! Welcome to the second issue of Promissory Notes - our banking and finance e-newsletter - for 2024. Business today is characterized by relentless change. To assist our clients in navigating...more
On June 26, the OCC issued Bulletin 2023-22 announcing recent updates to the agency’s approach to cybersecurity assessment procedures. The Cybersecurity Supervision Work Program (CSW) provides high-level examination...more
Regulatory Developments - FDIC Refines Supervisory Strategy Concerning Multiple Re-Presentment NSF Fees Guidance - On June 16, the FDIC revised its Supervisory Guidance on Multiple Re-Presentment Non-Sufficient Funds...more
The federal banking agencies have published new guidance to help banking organizations manage risks associated with third-party relationships, including relationships with financial technology (fintech) companies. The new...more
On April 21, the Financial Stability Oversight Council (FSOC) released a proposed analytic framework for financial stability risks, “intended to provide greater transparency to the public about how [FSOC] identifies,...more
The financial services sector must already contend with a maze of regulations in a variety of areas, and 2023 is poised to usher in new cybersecurity regulations for the industry. Organizations should ensure their security...more
Headlines: ..OCC Publishes Security Standards for Video Teleconferencing With Agency Staff ..CFPB Imposes Civil Penalty and Customer Refunds for Authorized-Positive Overdraft Fees ..Treasury Department Recommends...more
Regulatory Developments - OCC Acting Comptroller Issues Statement on Standards for Stablecoins - On April 27, Acting Comptroller of the Currency Michael J. Hsu issued a statement regarding stablecoin standards after his...more
In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed rules to include certain significant market participants as “dealers” or “government securities dealers” to essentially eliminate the trader exclusion...more
In This Issue. The Consumer Financial Protection Bureau (CFPB) announced a new initiative focused on financial issues faced by rural communities and also updated its examination procedures to cover unfair discrimination; the...more
In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed a new rule to increase market transparency regarding short selling and extended the comment period for its proposed rule requiring reporting on...more
In This Issue. The Federal Reserve Board of Governors (Federal Reserve), the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) released stress test scenarios to assess...more
In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed changes to private fund regulation; the Office of the Comptroller of the Currency (OCC) succeeded in validating its “valid-when-made” rulemaking; the...more
On November 23, 2021, the OCC, Federal Reserve Board, and FDIC issued a joint final rule that requires banking organizations and their service providers to report certain computer-security incidents. A computer-security...more
Following the SolarWinds and the Colonial Pipeline cyberattacks, the Biden Administration emphasized a shift toward mandatory cybersecurity requirements. Throughout 2021, government agencies issued new cybersecurity guidance,...more
On November 18, 2021, the Office of the Comptroller of the Currency (“OCC”), the Board of Governors of the Federal Reserve System (“Board”), and the Federal Deposit Insurance Corporation (“FDIC”) (collectively, the...more
Banking organizations must notify the appropriate agency within 36 hours of certain computer-security incidents; and banking service providers must notify affected banking organizations as soon as possible in the event of an...more
Welcome to our last Promissory Notes issue of 2021. As we all know, 2021 was another interesting year in the banking and finance industry, and we expect 2022 to be much the same. Our goal, as with all of our publications, is...more
On November 18, 2021, three US agencies – the Office of the Comptroller of the Currency (OCC), the Federal Reserve Board (FRB) and the Federal Deposit Insurance Corporation (FDIC) – issued a joint rule concerning...more
On November 18, 2021, the Federal Deposit Insurance Corporation (FDIC), the Board of Governors of the Federal Reserve System (FRB), and the Office of the Comptroller of the Currency (OCC) issued a joint final rule (the...more
As the year’s end approaches, the US Office of the Comptroller of the Currency (OCC), a primary US banking regulator, has published its Banking Supervision Operating Plan for 2022. As you might expect, much of the OCC’s...more
In This Issue. The Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC) and the Board of Governors of the Federal Reserve System (together, the Agencies) issued a final rule...more
Introduction - On November 18, federal banking agencies issued the long-awaited final rule, establishing data security incident response notification requirements for “banking organizations” and “bank service providers”...more
In response to increasingly frequent and sophisticated cybersecurity attacks on banks and bank service providers, the federal prudential banking regulators—the Office of the Comptroller of the Currency (OCC), the Board of...more