On June 14, the Office of the Comptroller of the Currency (OCC) published the spring edition of its Semiannual Risk Perspective, which discusses key issues facing banks. The good news is that the federal banking system saw...more
Please join Troutman Pepper Partners Chris Willis and James Stevens for a very special announcement about two new great tools for the financial services industry: The Troutman Pepper Financial Services blog and the Troutman...more
On April 26, the Texas Bankers Association and Rio Bank, McAllen, Texas filed a complaint in the U.S. District Court for the Southern District of Texas challenging the Consumer Financial Protection Bureau’s (CFPB or Bureau)...more
4/27/2023
/ Administrative Procedure Act ,
Community Financial Services Association ,
Constitutional Challenges ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Protection Act ,
Data Collection ,
Dodd-Frank ,
ECOA ,
Federal Funding ,
Final Rules ,
Financial Institutions ,
Financial Services Industry ,
Loans ,
SCOTUS ,
Section 1071
As promised (and discussed here), the Consumer Financial Protection Bureau (CFPB) issued its final rule under Section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Final Rule). Section 1071 amended...more
On September 21 and 22, chief executives from the nation’s seven largest banks faced questioning before Congress, marking the third time senior bank officers have testified before Congress in the last three years. Senators...more
In this episode of The Crypto Exchange, Troutman Pepper Consumer Financial Services Partner Ethan Ostroff welcomes James Stevens to examine recent crypto-related activities by banking regulators. Ethan and James discuss the...more
Banks with available-for-sale (AFS) securities have seen significant unrealized losses on their bond portfolios as interest rates have risen. While not an immediate cause for regulatory concern, the change in bond portfolios...more
On August 19, the Federal Deposit Insurance Corporation (FDIC) issued cease and desist letters to five cryptocurrency companies, demanding they refrain from making allegedly false and misleading statements about deposit...more
On January 18, the Office of the Comptroller of the Currency (OCC) conditionally approved an application by Social Finance Inc. (SoFi) to acquire Golden Pacific Bank, National Association, so long as the new bank does "not...more
On January 10, the Federal Trade Commission’s final rule, amending the Standards for Safeguarding Customer Information (Safeguards Rule) under the Gramm-Leach-Bliley Act (GLBA), became effective. We wrote about the final rule...more
On December 16, the Consumer Financial Protection Bureau (CFPB) issued orders to five companies offering buy now, pay later (BNPL) products. BNPL programs are designed to allow consumers to purchase goods and to defer payment...more
On October 18, consumer advocate groups and 19 state attorneys general wrote comment letters, urging banking regulators to denounce “rent-a-bank” arrangements between financial institutions and fintechs or other third-party...more
The Consumer Bankers Association (CBA), a trade group of retail financial institutions, recently sent a letter to the Consumer Financial Protection Bureau (CFPB) director, requesting increased supervision of financial...more
Nearly four years after the Consumer Financial Protection Bureau (CFPB) issued its final November 2017 "Payday, Vehicle Title, and Certain High-Cost Installment Loans" Rule (Payday Rule), we at long last have a compliance...more
On September 1, the Consumer Financial Protection Bureau (CFPB) issued a 900+ page notice of proposed rulemaking (NPRM) to implement the small business lending data collection requirements under Section 1071 of the Dodd-Frank...more
In the future, most de novo banks in the United States will be formed by existing payments and nonbank fintech companies that provide financial services, or groups of players in those industries that want to form a payments...more
The Department of Financial Protection and Innovation (DFPI) of California entered a settlement agreement with Chime Financial, Inc. (Chime), a neobank company that is not licensed to operate as a bank or otherwise exempt...more
Live Life Federal Credit Union, a $69 million-asset credit union based in Fraser, Michigan, recently consented to a cease-and-desist order issued by the National Credit Union Administration Board (NCUA). The enforcement...more
In a final act of his tenure, Brian Brooks, the acting Comptroller of the Currency (OCC) on January 14 finalized a rule to ensure “fair access to banking services provided by large national banks, federal savings...more
Troutman Pepper has produced a series of podcasts on legal and business issues faced by companies during the COVID-19 pandemic.
This episode features Troutman Pepper Financial Institutions lawyers Zayne Tweed (moderator) and...more
On November 20, the Office of the Comptroller of Currency (OCC) proposed a rule aimed at ensuring fair access to bank services, capital, and credit. Citing pushes from across the political spectrum to “de-bank” industries...more
New Rule Effective as of September 30 - The Federal Reserve’s revised control framework under the Bank Holding Company Act (BHCA) and Home Owners’ Loan Act (HOLA) issued on January 30, 2020 became effective on September 30...more
On September 15, the Conference of State Bank Supervisors (CSBS) announced that money transmitters operating in 40 or more states will be able to take advantage of a new, comprehensive exam designed to satisfy all state money...more
On September 15, the Conference of State Bank Supervisors (CSBS) announced that money transmitters operating in 40 or more states will be able to take advantage of a new, comprehensive exam designed to satisfy all state money...more
On September 15, 2020, after considerable delay and pursuant to a court settlement, the Consumer Financial Protection Bureau (CFPB) released its Outline of Proposals Under Consideration and Alternatives Considered for small...more
9/18/2020
/ Consumer Financial Protection Bureau (CFPB) ,
Data Collection ,
Dodd-Frank ,
ECOA ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
Minority-Owned Businesses ,
Regulatory Requirements ,
Rulemaking Process ,
SBREFA ,
Section 1071 ,
Small Business ,
Women-Owned Businesses