Financial institutions have utilized service providers for a multitude of purposes over many years. The use of service providers has not historically been a controversial issue, and financial institutions have always had an...more
But upon closer consideration, there is an interplay between a bank partner program and the Electronic Fund Transfer Act (EFTA) as implemented by Regulation E, particularly when it comes to timeframes for disputes, liable...more
9/15/2023
/ Bank Partnership Lending Programs ,
Bank Secrecy Act ,
Board of Governors ,
Consumer Financial Protection Bureau (CFPB) ,
EFTA ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
FinTech ,
Non-Bank Lenders ,
Non-Depository Institutions ,
OCC ,
Regulation E ,
Risk Management ,
Third-Party ,
UDAAP
On June 6, 2023, the Board of the Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, Agencies) issued...more
7/13/2023
/ Banking Sector ,
Board of Governors ,
Due Diligence ,
FDIC ,
Federal Reserve ,
Financial Services Industry ,
FinTech ,
Interagency Guidance ,
OCC ,
Risk Management ,
Third-Party
On April 26, 2023, the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) (collectively “Agencies”) each individually released supervisory guidance to ensure that each...more
On January 3, 2023, the Board of Governors of the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively the Agencies)...more