News & Analysis as of

Comment Period Banking Sector Rulemaking Process

Alston & Bird

FDIC Takes First Steps in Revising Supervisory Appeals Processes

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Our Financial Services Team examines a proposed rule by the Federal Deposit Insurance Corporation (FDIC) that would revise its process for institutions to appeal material supervisory determinations....more

Orrick, Herrington & Sutcliffe LLP

U.S. Senate banking committee requests extension for comment period on proposed leverage ratio rule

On August 8, several members of the U.S. Senate Committee on Banking, Housing, and Urban Affairs sent a letter to the heads of the Fed, the FDIC, and the OCC. The letter requested more rigorous data and analysis on the...more

Mayer Brown

FDIC’s New Recordkeeping Proposal

Mayer Brown on

Last month, the FDIC proposed rules related to FDIC pass-through insurance coverage. These rules could have a significant impact on bank-fintech partnerships, including some partnerships for programs that do not promise FDIC...more

Goodwin

Stress Test Scenarios Released for 2022

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In This Issue. The Federal Reserve Board of Governors (Federal Reserve), the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) released stress test scenarios to assess...more

Adams & Reese

CFPB Solicits Feedback on “Junk Fees” – Are New Regulations Coming?

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On January 26, 2022, the Consumer Financial Protection Bureau (CFPB) issued a request for public comment relating to “junk fees” consumers may be subjected to when engaging in financial services. So what exactly is a...more

Goodwin

SEC Proposes Changes to Private Fund Regulation

Goodwin on

In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed changes to private fund regulation; the Office of the Comptroller of the Currency (OCC) succeeded in validating its “valid-when-made” rulemaking; the...more

Goodwin

SEC Proposes New Round of Money Market Fund Reforms

Goodwin on

In This Issue. The U.S. Securities and Exchange Commission (SEC) voted to propose money market fund reforms; the SEC also proposed amendments to Rule 10b5-1 trading plans and to modernize and improve share repurchase...more

Goodwin

Tenth Circuit Upholds District Court’s Ruling Finding No Breach of Fiduciary Duties in Section 36(b) Case

Goodwin on

In This Issue. The federal bank regulators published frequently asked questions concerning the London Interbank Offered Rate transition; the Consumer Financial Protection Bureau (CFPB) confirmed an effective date for two...more

Goodwin

FHFA Eliminates Adverse Market Refinance Fee

Goodwin on

In This Issue. The Federal Housing Finance Agency (FHFA) announced that Fannie Mae and Freddie Mac will no longer charge lenders the Adverse Market Refinance Fee; the Federal Deposit Insurance Corporation (FDIC) is seeking...more

Goodwin

Financial Services Weekly Roundup: Madden Fix/Valid When Made Rule Faces New Challengers

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In the News. On the heels of a lawsuit challenging the Office of the Comptroller of the Currency’s (OCC) recently issued Madden fix/valid when made rule, eight state attorneys general filed suit challenging a similar rule...more

Proskauer - Blockchain and the Law

The Office of the Comptroller of the Currency Solicits Public Comments on the “Digital Activities” of Banks

On June 3, 2020, the Office of the Comptroller of the Currency (OCC) published an advance notice of proposed rulemaking (ANPR) to solicit public input on the “digital activities” of banks and the impact of emerging...more

ArentFox Schiff

Payments From America, With Love: Industry and CFPB Approach to Amending the Remittance Rule

ArentFox Schiff on

According to the World Bank and the Bureau, of the $613.5 billion worldwide dollar amount of remittance transfers in 2017, $148.5 billion was sent from the US in over 325 million remittance transfers, and $6.6 billion was...more

Goodwin

Bank Regulators Propose Fix to Madden Problem

Goodwin on

Last week, the Office of the Comptroller of the Currency (OCC) and Federal Deposit Insurance Corporation (FDIC) each issued a proposed rule designed to clarify that interest rates that are valid when a loan is made remain...more

BCLP

Last Chance for Financial Companies to Weigh in On New FTC Data Security Standards

BCLP on

For the first time in 17 years, the FTC is proposing significant increases to the information security standards which apply to those financial institutions that are regulated by the FTC and are not already subject to similar...more

Ballard Spahr LLP

CFPB seeks comment on its guidance and implementation support

Ballard Spahr LLP on

The CFPB has issued a request for information that seeks comment on its guidance and implementation support. Comments on the RFI must be received on or before 90 days after the date the RFI is published in the Federal...more

Morrison & Foerster LLP

CFPB Issues RFI on Inherited Regulations

On March 26, 2018, the Consumer Financial Protection Bureau (CFPB or “Bureau”) published a Request for Information (RFI) on the CFPB’s inherited regulations and inherited rulemaking authorities. The RFI is the ninth in a...more

Ballard Spahr LLP

CFPB seeks comment on public reporting of consumer complaint information

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The CFPB has issued a request for information that seeks comment on potential changes to the CFPB’s practices for the public reporting of consumer complaint information. ...more

Ballard Spahr LLP

CFPB seeks comments on its plan to assess the RESPA mortgage servicing rule

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On May 4, the CFPB announced that as part of its impending 5-year review of mortgage rules, it was proposing a plan to assess the effectiveness of the Real Estate Settlement Procedures Act (RESPA) mortgage servicing rule.  ...more

Womble Bond Dickinson

Federal Banking Agencies Propose “Enhanced Cyber Risk Management Standards” For the Largest Banks

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In a major new cybersecurity initiative the federal banking agencies have issued an advanced notice of proposed rulemaking (“APNR”) seeking comment on enhanced cybersecurity standards for banking entities with $50 billion or...more

Carlton Fields

Notice and Comment Like a Rock Star

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Musicians know they’ve created a hit when thirty-somethings have known all the song’s words since middle school. Likewise, most consumer finance lawyers recall verbatim Regulation Z’s guidance to lenders that, “The annual...more

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