News & Analysis as of

FRB Financial Services Industry

Goodwin

FRB Fines Utah Prepaid Debit Card Company $44 Million for Unfair and Deceptive Practices

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O​​​​​​​n July 19, 2024, the Federal Reserve Board announced it had fined a Utah-based company that offers prepaid debit cards $44 million for alleged unfair and deceptive practices as well as an alleged deficient consumer...more

Ballard Spahr LLP

Bank’s Digital Assets Business Strategy Draws Federal Reserve Scrutiny

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The Federal Reserve Bank of Philadelphia (the “Philly Fed”) recently executed an agreement (the “Agreement”) with Pennsylvania-based Customers Bank (and its Customers Bancorp, Inc. holding entity) (collectively, “Customers”)....more

Ballard Spahr LLP

Federal Agencies Finalize Reconsideration of Value Guidance

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A group of federal agencies have finalized reconsideration of value (ROV) guidance for residential real estate valuations. The agencies are the Comptroller of the Currency (OCC), Consumer Financial Protection Bureau (CFPB),...more

Ballard Spahr LLP

Supreme Court opens the door for more APA challenges by ruling that the right of action accrues when the rule first causes injury

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On July 1, 2024, the Supreme Court issued its opinion in Corner Post, Inc. v Board of Governors of the Federal Reserve System in which the Court determined when a Section 702 claim under the Administrative Procedure Act (APA)...more

Mayer Brown Free Writings + Perspectives

Supreme Court Expands Time To Challenge Agency Regulations

Corner Post, Inc. v. Board of Governors of the Federal Reserve System, No. 22-1008 - Yesterday, the Supreme Court held in a 6-3 decision that the six-year time limit to challenge a federal agency regulation under the...more

Latham & Watkins LLP

FRB Issues Report on Climate Scenario Analysis Pilot

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With regulators keeping close watch, the results underscore the need for ongoing climate risk management investment and adaptation within the financial sector. On May 9, 2024, the Board of Governors of the Federal...more

Ballard Spahr LLP

New research suggests proposed Regulation II revisions lowering debit card interchange fees will cost consumers up to $2 billion...

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In October 2023, the Federal Reserve Board issued a proposal to lower the maximum interchange fee that a large debit card issuer can receive for a debit card transaction. The due date for comments on this proposal, originally...more

Ballard Spahr LLP

OIG report finds CFPB can enhance certain aspects of its enforcement investigations process

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The Office of Inspector General (OIG) for the Federal Reserve Board and CFPB has issued a report on its evaluation of the CFPB’s process for conducting enforcement investigations.  OIG concluded that the CFPB can enhance...more

Cadwalader, Wickersham & Taft LLP

Trends in 2024: American Bar Association Banking Law Committee Insights

From January 18th to 20th, the American Bar Association’s Banking Law Committee of the Business Law Section held its winter meeting in Washington, DC. This meeting not only provides an excellent retrospective of the previous...more

Ballard Spahr LLP

Consumer Finance Monitor Podcast Episode: Understanding the Federal Reserve Board Proposal to Lower Interchange Fee Cap for Debit...

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Our special guest is Zarik Khan, Founder of Finsolute Advisors. In October 2023, the Federal Reserve Board issued a proposal to lower the maximum interchange fee that a large debit card issuer can receive for a debit card...more

Ballard Spahr LLP

SCOTUS to hear oral argument on February 20 to determine timing for facial challenges to federal regulations

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The U.S. Supreme Court has scheduled oral argument for Tuesday, February 20, 2024 in Corner Post, Inc. v Board of Governors of the Federal Reserve System. The question that the Supreme Court will decide is when a right of...more

Cadwalader, Wickersham & Taft LLP

Vice Chair Barr Speaks on Liquidity Risk Management and Preparation for Use of Discount Window

Last Friday, Michael Barr, the Federal Reserve Board’s (“FRB”) Vice Chair for Supervision, delivered remarks to the ECB Forum on Banking Supervision in Frankfurt, Germany entitled The Importance of Effective Liquidity Risk...more

Cadwalader, Wickersham & Taft LLP

FRB, FDIC, OCC and NCUA Testify at Congressional Oversight Hearings

This week, the Senate Banking Committee and the House Financial Services Committee held oversight hearings with leaders of the Federal Deposit Insurance Corporation (“FDIC”), Federal Reserve Board (“FRB”), the National Credit...more

Troutman Pepper

Federal Agencies Announce Increased Regulations Z and M Dollar Thresholds for Exempt Consumer Credit and Lease Transactions, and...

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On November 13, the Consumer Financial Protection Bureau (CFPB) and the Federal Reserve Board (Fed) announced increased dollar thresholds used to determine whether certain consumer credit and lease transactions in 2024 are...more

Latham & Watkins LLP

FRB Proposes to Lower Debit Card Interchange Fee

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A proposed rule would lower the maximum amount that large debit card issuers can charge merchants for each transaction. On October 25, 2023, the Board of Governors of the Federal Reserve System (FRB) published a proposal...more

Troutman Pepper

FSOC Votes Unanimously to Finalize Process for Designating Nonbanks for Federal Reserve Supervision

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On November 3, the Financial Stability Oversight Council (FSOC) voted unanimously to finalize the procedures for designating a nonbank financial company for Federal Reserve supervision. FSOC’s Interpretive Guidance aims to...more

Cadwalader, Wickersham & Taft LLP

A Further Look at the FRB’s Debit Interchange Cap Proposal

As we mentioned last week, the Federal Reserve Board (“FRB”) announced proposed changes to Regulation II (Debit Card Interchange Fees and Routing), which is the implementing regulation of the Durbin Amendment to the...more

Cadwalader, Wickersham & Taft LLP

Federal Reserve Board Proposes Adjusting Debit Interchange Caps in Accordance with the Durbin Amendment

The Federal Reserve Board announced proposed changes to Regulation II (Debit Card Interchange Fees and Routing), which is the implementing regulation of the Durbin Amendment to the Dodd-Frank Act....more

Cadwalader, Wickersham & Taft LLP

Federal Banking Agencies Finalize Community Reinvestment Act Rules

On Tuesday, the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board (“FRB”) and the Office of the Comptroller of the Currency (“OCC”) (together, the “Agencies”) issued a final rule to amend and update...more

Troutman Pepper

Lenders Take Note: Federal Banking Agencies Issue Long-Awaited Community Reinvestment Act Final Rule

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On October 24, the Federal Reserve Board (Fed), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the agencies) finally issued their long-awaited final...more

Cadwalader, Wickersham & Taft LLP

FRB Governor Bowman Speaks on Financial Stability

Last week, Federal Reserve Board (“FRB”) Governor Michelle Bowman gave a speech entitled Financial Stability in Uncertain Times, focusing on the “financial stability risks and vulnerabilities” she is most focused on....more

Ballard Spahr LLP

Federal Reserve considering revisions to debit card interchange fees

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The Board of Governors of the Federal Reserve (FRB) is holding an open meeting on October 25, 2023 to discuss proposed revisions to the Board’s debit interchange fee cap contained in Regulation II, which implemented the...more

Ballard Spahr LLP

Federal Reserve Board and FDIC expected to approve final Community Reinvestment Act rules at Oct. 24 meetings

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At its open Board meeting scheduled for October 24, 2023, the Federal Reserve Board is expected to approve its final rule amending its current regulation implementing the Community Reinvestment Act....more

Cadwalader, Wickersham & Taft LLP

Vice Chair Barr Speaks on Capital Endgame Proposal

On Monday, Michael Barr, the Federal Reserve Board’s (“FRB”) Vice Chair for Supervision, delivered remarks to the American Bankers Association Annual Convention entitled Capital Supports Lending regarding the Basel III...more

Cadwalader, Wickersham & Taft LLP

Industry Trades Really Don’t Like the Basel III Endgame Proposal

As we covered previously, on July 27, 2023, the U.S. prudential bank regulators (the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board (“FRB”) and the Office of the Comptroller of the Currency (“OCC”)...more

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