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CFPB Announces It Will Not Prioritize Enforcement And Supervision Of Its Small Business Lending Data Collection Rule Under The...

On May 1, the Consumer Financial Protection Bureau (CFPB) announced that it will not prioritize enforcement or supervision of its small business lending data collection rule (the “Rule”) implementing the requirements of...more

Developments in National Bank Act (NBA) Preemption: Illinois’ Interchange Fee Prohibition Act is Held Preempted by the NBA; Ninth...

For followers of developments related to National Bank Act (NBA) preemption and the United States Supreme Court’s related decision in Cantero v. Bank of America, N.A., 602 U.S. 205 (2024), the waning days of 2024 proved...more

OCC Issues Guidance Reminding Banks of Risks Associated with Refinancing Commercial Loans

With the amount of commercial real estate loans scheduled for maturity over the next several years expected to increase significantly, there is accompanying heightened risk that some borrowers may be unable to replace their...more

Suit Alleging FDIC Overdraft Overreach May Not Make Waves

When following supervisory scrutiny of fees charged to bank customers, the activities of the Consumer Financial Protection Bureau, or CFPB, are often the focus. The Minnesota Bankers Association and Lake Central Bank of...more

The Federal Reserve, FDIC and OCC Issue Final Guidance on Risk Management in Third-Party Relationships: Moore & Van Allen

On June 6, 2023, the Board of Governors of the Federal Reserve System (the Federal Reserve), the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC, and collectively with the...more

New Legal Challenge Emerges to FDIC’s Supervisory Guidance on Re-presentment and Non-Sufficient Funds Fees

When following supervisory scrutiny of fees charged to bank customers, the Consumer Financial Protection Bureau’s (CFPB) activities are often the focus. The Minnesota Bankers Association and Lake Central Bank of Minnesota,...more

Acting Comptroller Hsu Suggests a Potential Path Forward to Address Identified Gaps in the Regulatory Resolution Framework for...

In the fourteen years since the 2008 financial crisis, significant actions have been taken by Federal banking agencies to make the largest financial institutions more resilient and less likely to fail and to require planning...more

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