A bi-partisan group of nine Senators (five Republicans and four Democrats) recently sent a letter to Acting FDIC Chairman Martin Gruenberg to express their support for the industrial loan company (ILC) charter and to remind...more
The FDIC has issued new supervisory guidance (FIL-40-2022) on multiple non-sufficient funds (NSF) fees arising from the re-presentment of the same unpaid transaction. The guidance directly applies only to state-chartered...more
As we previously reported, the Office of the Comptroller of the Currency (“OCC”) rescinded its 2020 Community Reinvestment Act (“CRA”) final rule (the “2020 CRA Final Rule” or the “Rescinded Rule”) in December 2021 and has...more
Just one day after announcing that it was launching a new system to provide guidance to other agencies with consumer financial protection responsibilities on how the CFPB intends to enforce federal consumer financial laws,...more
After moving alone in 2020 to reform its Community Reinvestment Act (CRA) regulation, the Office of the Comptroller of the Currency (OCC) has joined the Federal Deposit Insurance Corporation (FDIC) and Federal Reserve Board...more
With Democrats now firmly in control of the FDIC, Acting Chairman Martin Gruenberg released a list of the FDIC’s priorities for 2022. His list of priorities included the following...more
On December 4, 2022, the OCC issued a final rule that rescinds its June 2020 Consumer Reinvestment Act (CRA) final rule and replaces it with a rule that is largely based on the OCC’s 1995 CRA rule that was adopted jointly...more
On April 1, 2021, the FDIC’s final rule issued in December 2020 revising its brokered deposits regulation became effective. The full compliance date for the final rule is January 1, 2022. The rule established a new...more
On January 15, 2021, just weeks after the FDIC issued its final rule (the Rule) establishing requirements the parent entity of an industrial bank or industrial loan company (collectively, ILC) must meet for the ILC to have...more
The FDIC has issued a final rule setting forth the conditions it will impose and the commitments it will require to approve a deposit insurance application from an industrial bank or industrial loan company (collectively,...more
The FDIC has issued a final rule that establishes a new framework for analyzing whether deposits made through deposit arrangements qualify as “brokered deposits” and amends the methodology for calculating the interest rate...more
The CFPB, OCC, Federal Reserve, FDIC, and NCUA have issued a proposed rule on the role of supervisory guidance....more
On July 31, 2020, the Office of the Comptroller of the Currency (OCC) approved the national bank charter application of Varo Bank, N.A., a wholly-owned subsidiary of fintech Varo Money, Inc. The approved application is for a...more
When the OCC issued its final Community Reinvestment Act (“CRA”) rule on May 20, 2020, the agency acted alone without waiting to achieve consensus with the FDIC, the agency with which the OCC had jointly issued its proposed...more
Over the past six weeks, opposition to the OCC’s Community Reinvestment Act (“CRA”) final rule has hardened on two fronts. The OCC’s decision to hurriedly issue the final rule on May 20, 2020 without achieving consensus with...more
On May 20, 2020, the OCC issued a final rule to “strengthen and modernize” its existing Community Reinvestment Act (“CRA”) regulations. This is the second in a series of five blog posts about the final rule....more
6/26/2020
/ Banks ,
Community Development ,
Community Reinvestment Act ,
Coronavirus/COVID-19 ,
FDIC ,
Federal Reserve ,
Final Rules ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Lending ,
Notice of Proposed Rulemaking (NOPR) ,
OCC ,
Performance Standards
On May 20, 2020, the OCC issued a final rule to “strengthen and modernize” its existing Community Reinvestment Act (“CRA”) regulations. According to the agency’s press release, the final rule is designed to increase...more
The FDIC has extended by 30 days the comment period on its proposed rule setting forth the conditions it would impose and the commitments it would require to approve a deposit insurance application from an industrial bank or...more
The FDIC has issued a proposed rule setting forth the conditions it would impose and the commitments it would require to approve a deposit insurance application from an industrial bank or industrial loan company...more
The OCC and FDIC announced yesterday that they have extended the 60-day comment period for their joint proposal to revise their regulations implementing the Community Reinvestment Act that was published in the Federal...more
The OCC and FDIC have issued a joint proposal to revise their regulations implementing the Community Reinvestment Act (CRA). Although the Federal Reserve, OCC and FDIC, are the primary CRA regulators, the Fed did not join...more
12/19/2019
/ Banks ,
Community Reinvestment Act ,
Consumer Financial Products ,
FDIC ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Financing ,
Joint Policy Statements ,
Lending ,
Low-Income Issues ,
Mortgages ,
OCC ,
Rulemaking Process
On October 10, 2019, the Board of Governors of the Federal Reserve System (Board), together with the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation, adopted a final rule to revise the...more
10/17/2019
/ Capital Requirements ,
Dodd-Frank ,
Economic Growth Regulatory Relief and Consumer Protection Act ,
FDIC ,
Federal Reserve ,
Final Rules ,
Financial Institutions ,
Financial Regulatory Reform ,
Foreign Banks ,
Liquidity ,
OCC ,
Prudential Standards ,
Risk-Based Approaches
On Tuesday, the FDIC released a Notice of Proposed Rulemaking (NPR) that outlines anticipated revisions to its regulations regarding interest rate restrictions that apply to less than well capitalized insured depository...more
The FDIC has issued an Advance Notice of Proposed Rulemaking (ANPR) seeking comment on its regulatory approach to brokered deposits and interest rate restrictions. ...more
In a recent interview (her first since being sworn in as Chair of the Federal Deposit Insurance Corporation), Jelena McWilliams provided insight into the FDIC’s likely regulatory agenda....more
8/14/2018
/ Capital Requirements ,
Community Reinvestment Act ,
Consumer Financial Products ,
Deposit Insurance ,
FDIC ,
Global Systemically Important Banks (G-SIBs) ,
Loans ,
National Bank Charters ,
Regulatory Agenda ,
Regulatory Burden ,
Regulatory Oversight ,
Volcker Rule