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Banking Sector Dodd-Frank Wall Street Reform and Consumer Protection Act Banks

Paul Hastings LLP

Preparing Banks for the Next Round of Challenges While the Sun Is Still Shining

Paul Hastings LLP on

Fifteen years ago, in the shadow of the 2008 financial crisis, Congress adopted the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank), the most significant change to financial regulation since the...more

Orrick, Herrington & Sutcliffe LLP

Fed and FDIC release the public sections of 64 banks’ living wills

On August 5, the Fed and FDIC released the public sections of 2025 resolution plans for the eight largest and most complex domestic banking organizations and 56 foreign banking organizations. The plans, as required by the...more

McGlinchey Stafford

CFPB to Reopen 1033 Open Banking Rulemaking

McGlinchey Stafford on

The Consumer Financial Protection Bureau’s (CFPB) open banking rules, issued under Section 1033 of the Dodd-Frank Act, have been the subject of ongoing litigation since their finalization late last year. The litigation is...more

Cadwalader, Wickersham & Taft LLP

Midyear Momentum, July 2025 - Federal Reserve Releases Results of Stress Tests

On June 27, the Federal Reserve Board issued the aggregate and individual results of the supervisory stress test (also known as the Dodd-Frank Act Stress Test or DFAST, as these tests are required by Section 165 of the...more

Orrick, Herrington & Sutcliffe LLP

OCC responds to association’s letter to rescind its preemption regulations

On June 9, the OCC rejected a request from a group of state bank supervisors to rescind its preemption regulations, affirming its position that its rules align with federal law, Supreme Court precedent, and recent executive...more

Cadwalader, Wickersham & Taft LLP

Heating Up, June 2025 - Vice Chair Bowman Gives Outline of Her Agenda Following Senate Confirmation

Last Friday, following her confirmation by the Senate as Federal Reserve Board Vice Chair of Supervision, Michelle Bowman laid out some of her priorities in a speech entitled “Taking a Fresh Look at Supervision and...more

Sheppard Mullin Richter & Hampton LLP

OCC Rejects Calls to Roll Back Preemption Rules

On June 9, Acting Comptroller of the Currency Rodney Hood issued a letter rejecting the Conference of State Bank Supervisors’ (CSBS) request that the OCC rescind its 2011 preemption regulations. The OCC ‘s letter signals...more

Goodwin

Consequences of Forming or Acquiring a Depository Institution

Goodwin on

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

Moore & Van Allen PLLC

Developments in National Bank Act (NBA) Preemption: Illinois’ Interchange Fee Prohibition Act is Held Preempted by the NBA; Ninth...

Moore & Van Allen PLLC on

For followers of developments related to National Bank Act (NBA) preemption and the United States Supreme Court’s related decision in Cantero v. Bank of America, N.A., 602 U.S. 205 (2024), the waning days of 2024 proved...more

Orrick, Herrington & Sutcliffe LLP

GAO says Fed, FDIC escalation processes could be improved

The GAO released its November 2024 report, titled “Bank Supervision: Federal Reserve and FDIC Should Address Weaknesses in Their Process for Escalating Supervisory Concerns,” to the U.S. Senate Committee on Banking, Housing,...more

Orrick, Herrington & Sutcliffe LLP

District Court case on interchange fees moves forward with intervenor motion

Recently, the U.S. District Court for the District of North Dakota received a motion from two banking associations seeking intervenor status in a case challenging Regulation II, which regulates interchange fees received by...more

Stinson LLP

CFPB Promotes Open Banking as it Issues Final Rule on Personal Financial Data Access Rights

Stinson LLP on

Time will tell whether the Consumer Financial Protection Bureau's (CFPB) stated goals of accelerating "open banking" and competition will come to fruition as a result of the long-awaited final rule implementing Section 1033...more

Orrick, Herrington & Sutcliffe LLP

Banking groups seek to halt CFPB’s 1033 rule

On October 23, one bank and two banking industry groups challenged the CFPB’s 1033 Rule that would mandate banks to share sensitive customer data, such as transaction history, account balances, and account and routing numbers...more

Kelley Drye & Warren LLP

CFPB Pushes Move to an Open Banking System with the Personal Financial Data Rights Rule and Sparks Immediate Court Challenges from...

Kelley Drye & Warren LLP on

On Tuesday, the Consumer Financial Protection Bureau (CFPB) released the final version of the Personal Financial Data Rights Rule that requires many financial institutions, credit card issuers, and other financial service...more

Orrick, Herrington & Sutcliffe LLP

CFPB receives first application for open banking standard setter recognition

On September 24, the CFPB received its first application for open banking standard setter recognition under Section 1033 of the Dodd-Frank Act. As previously covered by InfoBytes, the CFPB initiated its public comment period...more

Mintz - ML Strategies

2024 Pre-Election Analysis: Financial Services

Mintz - ML Strategies on

Financial services encompass a wide range of services offered by the nation’s financial institutions, including banking, mortgage, investment, and credit services. The next administration and Congress’s financial services...more

Nutter McClennen & Fish LLP

Nutter Bank Report: August 2024

CFPB Issues Filing Instructions Guide for Small Business Lending Data - The CFPB has published instructions for banks and other covered financial institutions to submit small business lending data that is required to be...more

Orrick, Herrington & Sutcliffe LLP

FDIC, Fed approve final resolution planning guidance

On July 30, the Fed and the FDIC published final guidance to enhance resolution planning at large banks. The guidance aims to assist certain larger financial institutions in developing their resolution plans, which are...more

Kilpatrick

Bank Regulators Revive Proposed Rules on Incentive Pay

Kilpatrick on

Three federal regulators have reproposed rules that implement the requirements for bank incentive compensation programs that were included in the Dodd-Frank legislation 14 years ago. Section 956 of Dodd-Frank required the...more

McGuireWoods LLP

(Some) Banking Agencies Repropose Dodd-Frank 956 Incentive Compensation Rules

McGuireWoods LLP on

Section 956 of the Dodd-Frank Wall Street Reform and Consumer Protection Act requires that six agencies — the Federal Reserve System (FRS), Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance...more

Orrick, Herrington & Sutcliffe LLP

FDIC releases comprehensive report on international, systemically important banks

On April 10, the FDIC released a report on the FDIC’s plans and readiness to step in as a receiver for a financial company under Title II of the Dodd-Frank Act. The FDIC Chairman said this report was the “most detailed...more

Hudson Cook, LLP

CFPB Bites of the Month - March 2024 - Here Comes the Sun and the CFPB

Hudson Cook, LLP on

In this month's article, we share some of our top "bites" covered during the March 2024 webinar. Bite 10: CFPB Issues Statement on Privacy and Personal Data - On February 28, 2024, the CFPB issued a statement on...more

American Conference Institute (ACI)

[Event] 8th Forum on FinTech & Emerging Payment Systems - April 9th - 10th, New York, NY

ACI’s 8th Annual Legal, Regulatory, and Compliance Forum on Fintech & Emerging Payment Systems will provide in-depth guidance on the latest regulatory developments at the Federal and State Level that you need to be aware of....more

Orrick, Herrington & Sutcliffe LLP

Senators call for stronger Fed oversight over bank mergers

On August 9, Senators Sherrod Brown (D-OH), Elizabeth Warren (D-MA), Jack Reed (D-RI), and John Fetterman (D-PA) wrote a letter to the Chair and Vice Chair of Supervision for the Board of Governors of the Federal Reserve...more

Sheppard Mullin Richter & Hampton LLP

SEC’s Proposed Conflicts of Interest Rule May Impede Hedging

Critics are warning that the SEC’s recently proposed rule (the “Proposed Rule”) prohibiting conflicts of interest in asset-backed securities (ABS) transactions may impede the ability of financial institutions, broker-dealers...more

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