Recently, the CFPB issued a “Request for Information Regarding Fees Imposed by Providers of Consumer Financial Products or Services.” Comments on the RFI must be submitted by March 31, 2022....more
The CFPB, Federal Reserve Board, FDIC NCUA, OCC, in conjunction with the state bank and state credit union regulators, jointly issued a statement on managing the transition away from LIBOR (Joint Statement)....more
The White House announced this past Thursday that President Biden has nominated Saule Omarova to serve as Comptroller of the Currency....more
Last week, the Federal Reserve Board published a paper on partnerships between community banks and fintech companies, “Community Bank Access to Innovation through Partnerships.” The Fed’s publication of the paper is another...more
The OCC, FDIC, and Federal Reserve Board have issued a guide that is intended to assist community banks in conducting due diligence when considering relationships with financial technology (fintech) companies (Guide)....more
This past Tuesday, Acting Comptroller of the Currency Michael Hsu appeared as a witness at the Senate Banking Committee’s hearing, “Oversight of Regulators: Does our Financial System Work for Everyone?”...more
On Thursday, July 29, the Senate Banking Committee will hold a hearing entitled, “Protecting Americans from Debt Traps by Extending the Military’s 36% Interest Rate Cap to Everyone.” ...more
The FDIC has filed its reply in support of its motion for summary judgment in the lawsuit filed by a group of state attorneys general to set aside the FDIC’s “Madden-fix” rule. The reply responds to the AGs’ opposition to...more
The Federal Reserve, FDIC, and OCC released on July 13, 2021 proposed guidance for banking organizations on managing risks associated with third-party relationships, including relationships with financial technology-focused...more
The Federal Reserve, FDIC, and OCC have released proposed guidance for banking organizations on managing risks associated with third-party relationships, including relationships with financial technology-focused entities such...more
The state attorneys general have filed their opposition to the FDIC’s motion for summary judgment in their lawsuit to set aside the FDIC’s “Madden-fix” rule. The filing also includes the AGs’ reply to the FDIC’s opposition...more
The D.C. federal district court hearing the lawsuit filed by the Conference of State Bank Supervisors (CSBS) seeking to block the Office of the Comptroller of the Currency from granting a national bank charter to Figure...more
The FDIC has filed a motion for summary judgment in the lawsuit filed by the Attorney Generals of six states and District of Columbia to set aside the FDIC’s “Madden-fix” rule. The filing also includes the FDIC’s opposition...more
Yesterday, by a vote of 52-47, the Senate passed the resolution introduced by Democratic Senators under the Congressional Review Act (CRA) to overturn the OCC’s “true lender” final rule. The rule addresses when a national...more
The Attorney Generals of the six states and District of Columbia who filed a lawsuit against the FDIC to set aside its “Madden-fix” rule have filed a motion for summary judgment in the case. ...more
The OCC announced today that it is pausing publication of its final fair access rule in the Federal Register to “allow the next confirmed Comptroller of the Currency to review the final rule and the public comments the OCC...more
The OCC has issued a final rule establishing standards that a bank must follow in fulfilling its obligation to provide fair access to financial services. The final rule is effective on April 1, 2021....more
Less than two months after issuing its final “Madden fix” rule, the OCC has now issued a proposed rule to address when a national bank or federal savings association should be considered the “true lender” in the context of a...more
7/22/2020
/ Consumer Financial Products ,
Financial Regulatory Reform ,
Financial Services Industry ,
HOLA ,
Interest Rates ,
Madden v Midland Funding ,
National Bank Act ,
Non-Bank Lenders ,
OCC ,
Rulemaking Process ,
True Lender
PayPal has filed a motion for summary judgment in its lawsuit against the CFPB seeking to invalidate the Bureau’s prepaid card rule (“Rule”). The Rule became effective on April 1, 2019....more
The CFPB’s final rule on prepaid accounts, which became effective on April 1, 2019, requires issuers of prepaid accounts, with certain exceptions, to submit to the CFPB all account agreements that the issuer offers, amends,...more
10/25/2019
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Agreements ,
Databases ,
Disclosure Requirements ,
Final Rules ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Online Platforms ,
Prepaid Payment Products ,
Regulatory Requirements ,
Rulemaking Process ,
Websites
After several years of rulemaking, amendments, and delays, the CFPB’s Prepaid Rule (the “Rule”) is finally set to take effect on April 1, 2019. ...more
After several years of rulemaking, amendments, and delays, the Consumer Financial Protection Bureau's (CFPB) Prepaid Rule is finally set to take effect on April 1, 2019. ...more
A Minnesota federal district court recently ruled that lead generators for a payday lender could be liable for punitive damages in a class action filed on behalf of all Minnesota residents who used the lender’s website to...more
A new bulletin issued by the Office of the Comptroller of the Currency (OCC), Bulletin 2018-23, makes slight, but significant, changes to OCC policy regarding when evidence of illegal or discriminatory credit practices could...more