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Consumer Finance Monitor Episode: How the CFPB Is Using Interpretive Rules to Expand Regulatory Requirements for Innovative Consumer Financial Products; Part One: Buy-Now, Pay-Later
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On Sept. 17, 2024, the Federal Deposit Insurance Corporation (FDIC) Board met to finalize an updated approach to increase scrutiny of bank mergers, particularly those that would result in a bank with over $100 billion in...more
When federal agencies review bank mergers, the competition issues typically relate to the number and location of physical branches and the extent of any overlap in the areas served. By contrast, the proposed $35 billion...more
Introduction - On 29 January 2024, the Office of the Comptroller of the Currency (OCC) issued a notice of proposed rulemaking (NPR) regarding its review of Bank Merger Act (BMA) applications. The NPR was released immediately...more
The Situation: On January 29, 2024, the Office of the Comptroller of the Currency ("OCC") requested comment on a proposed rule updating its bank merger rules and incorporating a policy statement (the "Proposal") on agency...more