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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week....more
On September 17, 2024, the FDIC board approved a notice of proposed rulemaking that would increase recordkeeping obligations for bank deposits received from third party, non-bank companies that accept those deposits on behalf...more
The FDIC has issued a proposed rule that would apply to practically all bank-fintech arrangements that use custodial deposit accounts to provide customers with transactional features (also called "FBO" accounts for short)....more
Becoming or owning an industrial loan company (or ILC)—the elusive "nonbank bank" option, as Congress coined the term in 1987— still has an allure for financial services providers that want to (1) lend on a national scale...more
In late July 2024, the Federal Deposit Insurance Corporation (FDIC) board of directors proposed a rule that would revise its standards on banks accepting brokered deposits. The proposed rule would expand the definition of...more
CFPB Issues Filing Instructions Guide for Small Business Lending Data - The CFPB has published instructions for banks and other covered financial institutions to submit small business lending data that is required to be...more
“In the worst case, these [newly designated brokered deposits] will have to get offloaded in a way that potentially puts those banks at even greater liquidity risk, especially to the extent that they have a higher...more
To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more
The FDIC recently proposed a rule that would substantially change the 2020 final rule on brokered deposits that largely liberalized the FDIC’s framework. The proposed rule would eliminate many of the changes from 2020 and...more
On July 30, 2024, the FDIC proposed revisions to the restrictions on brokered deposits. The revisions would undo many of the key elements of the 2020 revisions, and would dramatically expand the number of deposit brokers and...more
On July 30, 2024, the FDIC proposed substantive changes to the 2020 Brokered Deposit Rule (2020 Rule) that, if finalized, could meaningfully impact a wide group of bank and nonbank stakeholders who rely on the current rule’s...more
The FDIC board on July 30 approved a notice of proposed rulemaking intended to strengthen the prudential protections of the agency’s safety and soundness rule for brokered deposits (12 CFR 337.6)....more
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
The proposal seeks to make executive compensation arrangements more sensitive to risk and would require complex risk management programs to ensure compliance....more
On May 6, the Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC), and Federal Housing Finance Agency (FHFA) issued a notice of proposed rulemaking and request for public comment to...more
On March 21, 2024, the Federal Deposit Insurance Corporation (“FDIC”) approved a Federal Register notice seeking public comment on its proposal to revise its current Statement of Policy on Bank Merger Transactions. Among the...more
In this month's article, we share some of our top "bites" for the prior and current month covered during the January 2024 webinar....more
A recent OCC report identified key issues facing the federal banking system, including increasing credit risk due to higher interest rates, increasing risk in commercial real estate lending, prolonged inflation, declining...more
The federal banking agencies have jointly issued a final rule that will modify how examiners assess compliance with the Community Reinvestment Act (CRA). Among other changes to the CRA regulations announced on October 24, the...more
The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more
In Short: The Situation: The Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, and Federal Deposit Insurance Corporation (collectively, the "Agencies") have proposed rules...more