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1. Factors with Strongest Potential to Affect Near-Term Economy Respondents were asked, over the next six months, which two factors had the strongest potential to affect the economy. Even though the 2024 election is in the...more
Effective November 23, 2024, the Texas Department of Savings and Mortgage Lending (the “DSML”) adopted new rules affecting mortgage loan companies, mortgage bankers, individual residential mortgage loan originators, and...more
While existing regulations won't be erased overnight, the Trump Administration can quickly rescind informal agency guidance, including advisory opinions, interpretive rules and policy statements, creating opportunities for...more
On November 13, the Consumer Financial Protection Bureau released a “pilot study” on the small business lending market revealing “significant disparities” in how lenders treat black and white small business owners. As part of...more
On October 3, the OCC issued Bulletin 2024-29, providing guidance for managing credit risk in connection with refinancing commercial loans. The bulletin is directed at all banks with commercial loan portfolios, and...more
With inflation continuing to impact the US economy, lenders are focused on the economic impact of elevated interest rates. Lenders’ expectations for the US economy’s performance in the longer term – beyond the next six months...more
In the latest development to challenges to the CFPB’s 1071 rulemaking, plaintiff trade associations, including the American Bankers Association and the Texas Bankers Association, have filed a motion for summary judgment...more
On February 5, several trade groups, including the American Bankers Association, the Independent Community Bankers of America, and the U.S. Chamber of Commerce, filed suit against the Federal Reserve Board, the FDIC, and the...more
Interest rates and inflation have been the big drivers of the US economy as of late, but lenders are increasingly optimistic for 2024, despite some challenges. Lenders foresee interest rate declines beginning in 2024 – with...more
On October 24, 2023, the Office of the Comptroller of the Currency, the Federal Reserve Board, and the Federal Deposit Insurance Corporation issued a final rule to strengthen and modernize regulations implementing the...more
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, specifically focusing on:...more
Our monthly regulatory newsletter monitors all relevant developments regarding German and European regulatory law in English language. In addition, we prepare an overview of articles and court decisions published in...more
Die Bundesanstalt für Finanzdienstleistungsaufsicht („BaFin“) hat am 29. Juni 2023 die siebte Novelle der Mindestanforderungen an das Risikomanagement der Banken („MaRisk“) veröffentlicht. Die MaRisk kodifizieren die...more
For many borrowers, pricing is the most significant factor when deciding on a lender. If you are borrowing from a mid-market lender (MML), it is more than likely that the deal will be papered on that MML's standard form...more
On February 8, the U.S. District Court for the Northern District of California ruled against three states – California, Illinois, and New York – challenging the OCC’s rule on the “valid when made” doctrine. In 2020, the OCC...more
On June 29, NYDFS announced that two New York-charted banks engaging in indirect auto lending will pay civil money penalties for violating New York’s fair lending law for engaging in practices that resulted in members of...more
The Reserve Bank of India (RBI) has announced a series of policy changes, which include (i) the relaxation of its External Commercial Borrowing (ECB) framework and (ii) the withdrawal of certain restrictions on investment by...more
On 22 January 2018, two of the largest ‘buy now, pay later’ businesses in Australia, Afterpay and Zip.co, appeared at a hearing before the Senate’s Economic References Committee. During the Senate hearing, both Zip.co and...more
A recent FDIC request for information (RFI) suggests the FDIC is interested in enabling banks to offer small, short-term loans to consumers. Over the coming weeks the FDIC will be taking comments on the matter. After...more
Earlier this month, the Federal Deposit Insurance Corporation (FDIC) published a Request for Information (RFI) seeking public comment on issues related to small-dollar lending by FDIC-supervised financial institutions. ...more
On October 12, 2017, the OCC issued OCC Bulletin 2017-40 announcing the release of its Policies and Procedures Manual 5000-43 (PPM 5000-43), which outlines the OCC’s policy and framework for how the agency determines...more
Bryan Cave attorney Jerry Blanchard joins hosts Jonathan Hightower and Rob Klingler in the studio today to discuss High Volatility Commercial Real Estate (HVCRE) loans....more
In a notice published in today’s Federal Register, the CFPB announced that it has extended the comment period on its small business lending RFI until September 14, 2017....more
As required by the President’s Executive Order 13772 setting forth the core principles that should be taken into account in connection with the regulation of the U.S. financial system, the U.S. Treasury Department published a...more
As 2017 begins, financial markets and the regulators that oversee them are facing significant uncertainty. When President-elect Donald Trump assumes the Oval Office on Jan. 20, all indications suggest that it will mark a...more