In the last week, the Federal Reserve has announced two forthcoming dates when the Fed would be releasing two important announcements: (1) the results of its annual bank stress tests will be released on June 23 at 4:30 p.m....more
On May 5, 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 notice of proposed rulemaking to...more
5/9/2022
/ Banks ,
Comment Period ,
Community Reinvestment Act ,
Consumer Financial Products ,
FDIC ,
Financial Regulatory Reform ,
Financial Services Industry ,
FRB ,
NPRM ,
OCC ,
Regulatory Agenda ,
Regulatory Requirements
Last week, six bank trade associations, including the Bank Policy Institute and the American Bankers Association, submitted a joint comment letter on the Federal Reserve’s re-proposed Guidelines for access to Fed accounts and...more
On March 8, the Federal Register published the Federal Reserve Board’s supplemental notice and request for comment on updates to its proposed guidelines for Federal Reserve Banks to utilize in evaluating requests for access...more
On February 11, 2022, the U.S. District Court for the District of Delaware granted a motion for interlocutory appeal in Consumer Financial Protection Bureau v. The National Collegiate Master Student Loan Trusts filed by...more
2/16/2022
/ Appellate Review ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Covered Person ,
Debt Collection ,
Enforcement Actions ,
Enforcement Authority ,
Financial Services Industry ,
Interlocutory Appeals ,
Statutory Interpretation ,
Statutory Violations ,
Student Loans ,
Unfair or Deceptive Trade Practices
I. Introduction -
The Office of the Comptroller of the Currency (“OCC”) continues along its cautious course of allowing fintech and digital asset firms into the so-called “regulatory perimeter,” not through any special...more
I. Introduction -
As we note in our companion memorandum, the Office of the Comptroller of the Currency (“OCC”) continues along its cautious course of allowing fintech and digital asset firms into the so-called...more
On June 30, 2021, President Biden signed a joint resolution of Congress under the Congressional Review Act (“CRA”) to disapprove the OCC’s True Lender Rule. As a result, the True Lender Rule is now repealed....more
On May 11, the Senate voted 52-47 (with three Republicans joining 49 Democrats) to pass a joint resolution under the Congressional Review Act (“CRA”) to disapprove of (i.e., rescind) the Office of Comptroller of the...more