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CFPB states the Section 1033 Open Banking rule exceeds its authority

In its motion for a summary judgment in a lawsuit challenging the regulation, the CFPB stated it has concluded that the Section 1033 Rule (Rule) exceeds the agency’s statutory authority to create an open banking system...more

CFPB will kill Section 1033 Open Banking Rule

The CFPB is planning to repeal its Section 1033 Open Banking Rule, according to a filing in a federal lawsuit challenging the rule. On the same day the Final Rule was issued, the Banking Policy Institute (BPI) and Kentucky...more

Oregon Considering DIDMCA Opt-Out Legislation

Oregon may become the latest state attempting to stop out-of-state banks from “exporting” home-state interest rates on loans made to Oregon consumers. Like similar legislation adopted by Colorado in 2023, House Bill 2561...more

NY State Department of Financial Services issues proposed overdraft rule

The New York State Department of Financial Services has released a proposed rule that would regulate overdraft, non-sufficient funds (NSF), and return deposit item fees charged by banks, trust companies, savings banks,...more

CFPB re-establishes regulatory sandbox, no-action letter programs

In an effort to foster innovation in financial services, the CFPB is reinstituting its programs that allow companies to obtain regulatory safe harbors through no-action letters and sandboxes to test new products and services....more

Bank associations seek a preliminary injunction to block CFPB overdraft rule

Mississippi Bankers Association, the American Bankers Association, the Consumer Bankers Association, America’s Credit Unions, and three banks are seeking a preliminary injunction blocking the CFPB from implementing the...more

CFPB issues overdraft rule prior to administration change

The CFPB has issued its long-awaited final rule that covers overdraft policies at financial institutions with at least $10 billion in assets. The final rule offers those financial institutions three options for designing...more

FDIC board approves NPRM that would increase recordkeeping for custodial accounts

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

FDIC Issues Notice of Proposed Regulations for Enhanced Recordkeeping for Third-Party Custodial Accounts

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

CFPB Reminds Financial Institutions to Retain Records of Affirmative Consent for Overdraft Opt-in

On September 17, 2024, the CFPB issued Consumer Financial Protection Circular 2024-05 on improper overdraft practices. The circular reminded financial institutions of their obligation to retain records that prove the consumer...more

CFPB Takes Aim at Cash Back Fees

Some dollar store chains and other retailers now are charging consumers for obtaining cash back on debt or prepaid card purchases—transactions that generally have been free in the past–the CFPB reported....more

Bank Regulators Issue Statement on Third-Party Relationships with Financial Institutions and Publish Request for Information on...

The federal banking regulators (The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation) issued on July 25 a lengthy joint statement...more

Banking Regulators Seek Comment on Third-Party Relationships with Financial Institutions

The federal banking regulators are seeking comment to better understand the relationship between financial institutions and third parties that work for them....more

New Florida Law Prohibits Banks from Considering Customers’ Political, Religious Beliefs

A Florida law that prohibits federal and state depository institutions conducting business in the state from denying services based on religion or political beliefs and activities went into effect on July 1....more

Witnesses Tell House Subcommittee That Regulators Risk Hampering Fintech-Bank Partnerships

Federal and state regulators risk stifling competition as they continue to develop a regulatory regime for fintech relationships with financial institutions, witnesses told a House subcommittee last week....more

Colorado provides some (but not enough) guidance on new general-purpose credit card carve-out

In the same 2023 bill (House Bill 23-1229) that included Colorado’s DIDMCA opt-out**, Colorado adopted a statute excepting certain “general-purpose credit cards”, as defined, from the state’s limitations on finance charges...more

Fifth Circuit (again) rejects transfer of credit card late fee case to D.C.

On June 19, 2024, the Fifth Circuit dissolved the district court’s order transferring the case challenging the CFPB’s credit card late fee rule. In granting the writ of mandamus filed by the plaintiff trade associations...more

Transfer Redux: Once again, CFPB Late Fee litigation transferred from Texas to DC, transfer challenged in Fifth Circuit

In a replay of earlier events, in response to an emergency petition for writ of mandamus and administrative stay of transfer filed by the plaintiffs in the lawsuit challenging the legality of the CFPB’s credit card late fee...more

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