Climate Risk, the emerging risk
Consumer Finance Monitor Podcast Episode: Community Reinvestment Act Reform: A Close Look at the Final Rule
Consumer Finance Monitor Podcast Episode: What the Recent Developments in Federal Preemption for National and State Banks Mean for Bank and Nonbank Consumer Financial Services Providers
Federal Banking Interagency Final Guidance on Third-Party Relationships - The Consumer Finance Podcast
Corruption, Crime and Compliance : CFPB and OCC Hit Bank of America with $250 Million Penalty for Consumer Abuse Practices
CFPB's Section 1071 Final Rule (Part 3): Potential Problem Areas – The Consumer Finance Podcast
Crypto Year in Review 2022: Federal Reserve and Central Bank Digital Currencies and FDIC/OCC Regulatory Developments - The Crypto Exchange Podcast
Crypto Enforcement Is Here, and Always Has Been
Congressional and Federal Agency Action Following Executive Order on Digital Assets Policy
Guidepost in Motion: Banking on Crypto
Compliance into the Weeds: Episode 161-OCC Guidance on 3rd Party Risk Management
Episode 127 -- Deep Dive into the OCC Enforcement Action Against Wells Fargo CEO and Senior Executives
Dealing with an Unsolicited Offer - The Bank Account
The Community Reinvestment Act (CRA): Recap and What to Expect in 2014
The New Normal: Taking Responsibility for Your Vendors
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 30, the Federal Reserve Board (“FRB”), Federal Deposit Insurance Corporation (“FDIC”), Office of the Comptroller of the Currency (“OCC”) and the National Credit Union Administration (“NCUA”) finalized their Policy...more
On June 29, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, and the National Credit Union Administration (collectively, the agencies)...more
On February 8, 2022, a federal district court in California issued separate orders concluding that the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) did not violate the...more
Under the long-recognized valid when made doctrine, if a loan was not subject to a state usury law when it was made, it does not subsequently become even if it is subsequently sold or assigned to another party. The doctrine...more
A&B ABstract: On October 27, 2020, the Office of the Comptroller of the Currency (“OCC”) issued a noteworthy final rulemaking that sets forth when a national bank or federal savings association originates a loan and is deemed...more
In the News. The Consumer Financial Protection Bureau (CFPB) granted a no-action letter (NAL) regarding a proposed small-dollar credit product and sought comment on the CFPB’s plan to study how consumers locate, comprehend...more
The Office of the Comptroller of the Currency (“OCC”) issued its long-anticipated final rule on Oct. 27, to establish a “simple, bright-line test” to determine when a national bank or federal savings association has made a...more
In the News. On the heels of a lawsuit challenging the Office of the Comptroller of the Currency’s (OCC) recently issued Madden fix/valid when made rule, eight state attorneys general filed suit challenging a similar rule...more
On July 20, 2020, the Office of the Comptroller of the Currency (OCC) issued a notice of proposed rulemaking that would establish when national banks or federal savings associations (collectively, banks) are the “true lender”...more
On November 18, 2019, the Office of the Comptroller of the Currency (OCC) took action to reaffirm the “valid when made” doctrine in response to the uncertainty on the validity of interest rates of bank-originated loans sold...more
In This Issue. The Office of the Comptroller of the Currency (OCC) released its annual supervision operating plan outlining its bank supervision priorities, issued an updated Truth in Lending Act booklet, and provided...more
The U.S. Office of the Comptroller of the Currency issued a bulletin encouraging banks to offer responsible short-term small-dollar loans to help meet the credit needs of their customers. The OCC reminded banks, however,...more
In a recent interview, Comptroller of the Currency Joseph Otting, announced the OCC’s plan to “clarify” its support of bank-offered deposit advance products. “Deposit advance products” are typically defined as small-dollar,...more
Since the financial crisis, it has been difficult for consumers and developers to obtain mortgages to buy and build in the areas most hurt by the recession. The Office of the Comptroller of the Currency (OCC) has...more
Editor's Note - Supreme Court Limits SEC’s Disgorgement Powers. On June 5, the United States Supreme Court ruled unanimously in Kokesh v. Securities and Exchange Commission that disgorgement in a Securities and Exchange...more
The bulletin requires relationships between banks and marketplace lenders to be treated with the same rigor of due diligence and ongoing oversight as other relationships with third parties. On January 24, the Office of...more
According to Politico, the CFPB, OCC, Fed and FDIC have launched a review of bank sales practices, with the reviews to be conducted as special reviews rather than as part of the regular examination process....more
On February 12, the Office of the Comptroller of the Currency (“OCC”) released the “Installment Lending” portion of the Comptroller’s Handbook. OCC regulators utilize this document in connection with regulation of national...more
1. Question: What is the Volcker Rule, and when does it take effect? Answer: The Volcker Rule was enacted into law as section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank...more