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This second installment in a series of insights on bank charter considerations describes the consequences of operating through an insured depository institution charter, including capital requirements, supervision and...more
In light of ongoing litigation and the Trump administration’s new policy approach, federal banking agencies intend to rescind the 2023 CRA final rule and revert to pre-2023 standards....more
The Federal Deposit Insurance Corporation (“FDIC"), Federal Reserve Board (“FRB”), and the Office of the Comptroller of the Currency (“OCC”) (collectively, “the Agencies”) announced, that they intend to issue a proposal to...more
On March 28, the FDIC, the Fed, and the OCC announced their intention to issue a proposal to rescind the CRA final rule that was issued in October 2023 (covered by InfoBytes here). According to the prudential regulators, this...more
On March 28, the Federal Reserve Board, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (together, the federal banking agencies) announced their intent to rescind the...more
As all CRA officers know by now on December 19, 2024, the agencies announced the new size thresholds to determine what asset size qualifies as a “small bank”, “intermediate-small bank”, and “large bank” for CRA purposes. The...more
On October 3, the FDIC released an updated list of state nonmember banks examined for compliance under the CRA. The Financial Institutions Reform, Recovery, and Enforcement Act of 1989 requires public disclosure of...more
On August 5, the FDIC released an updated list of banks evaluated for compliance with the CRA in May, June, July and August. In May, the FDIC disclosed a list of evaluations of 56 banks, of which two were rated “outstanding,”...more
On July 18, the OCC, FDIC, and the Fed (the federal banking agencies or FBAs) submitted a brief requesting that the U.S. Court of Appeals for the Fifth Circuit hold oral argument and reverse the U.S. District Court for the...more
On July 12, the FDIC, Fed, and OCC released a list of distressed or underserved nonmetropolitan middle-income areas eligible for CRA credit. The list identified regions where banks’ revitalization or stabilization activities...more
Headlines 1. Supreme Court Upholds the Constitutionality of the CFPB’s Funding Structure The Supreme Court has ruled that the statutory authorization that allows the CFPB to draw funds from the earnings of the Federal Reserve...more
The CFPB has issued a policy statement that provides an analytical framework for identifying what constitutes an abusive act or practice under the Consumer Financial Protection Act of 2010 (CFPA). The new guidance published...more
Editor's Note - The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency,...more
The SEC has issued a controversial 886-page final rule imposing climate-related disclosure requirements on publicly traded companies, including banking organizations, which will require them to include certain climate-related...more
On March 8, the Fed, OCC, and FDIC (the federal banking agencies, or “FBAs”) submitted a brief opposing the plaintiffs’ motion for a preliminary injunction to stop the CRA final rule from going into effect. As previously...more
On March 4, the FDIC released a list of state nonmember banks evaluated for compliance with the Community Reinvestment Act (CRA) for March. The FDIC evaluated 56 banks with four ratings: Outstanding, Satisfactory, Needs to...more
On February 2, OCC and the FDIC released their Community Reinvestment Act (CRA) evaluations. The OCC disclosed a list of evaluations of national banks, federal savings associations, and insured federal branches of foreign...more
On February 5, a group of trade, banking, and business associations filed a class-action complaint for injunctive relief against the OCC, Federal Reserve, and FDIC (the Agencies) for their enforcement of the new rulemaking...more
On October 24, 2023, the OCC, FDIC and Board of Governors of the Federal Reserve System jointly adopted final amendments to their regulations implementing the Community Reinvestment Act of 1977 (CRA). In this episode, which...more
The Fed, FDIC, and OCC have extensively revised rules implementing the Community Reinvestment Act (CRA), a 1977 law to encourage banks to help meet the credit needs of their communities, especially in low- and moderate-income...more
After more than five years—with competing developments at times—the federal banking agencies (Federal Reserve, OCC, and FDIC) have revamped the regulations that implement the Community Reinvestment Act (CRA). The final...more
The federal banking agencies have jointly issued a final rule that will modify how examiners assess compliance with the Community Reinvestment Act (CRA). Among other changes to the CRA regulations announced on October 24, the...more
The Federal Deposit Insurance Corporation will launch a new portal to provide a more efficient means for bank personnel to respond to information and document requests during the consumer and Community Reinvestment Act...more
On September 5, the FDIC released the list of nonmember banks examined for compliance with the Community Reinvestment Act (CRA), which is intended to “encourage insured banks and thrifts to meet local credit needs.” ...more
On April 28, the FDIC issued FIL-22-2023 to provide regulatory relief to financial institutions and help facilitate recovery in areas of Oklahoma affected by severe storms, straight-line winds, and tornados from April 19 to...more