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Ballard Spahr LLP

Trump issues Executive Order prohibiting ‘debanking’

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President Trump has issued an Executive Order directing banking agencies to adopt policies to ensure that financial institutions do not use reputational risk as a basis for restricting access to banking services—a process...more

Troutman Pepper Locke

Federal Banking Agencies Propose Rescission of 2023 CRA Final Rule and Reinstatement of 1995 CRA Regulations

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On July 16, the Federal Reserve Board, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the federal banking agencies) jointly published a proposed rule...more

Ballard Spahr LLP

Federal banking agencies seek information on actions to address payments fraud

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On June 20, 2025, the Office of the Comptroller of the Currency (OCC), Treasury, the Board of Governors of the Federal Reserve System (FRB), and the Federal Deposit Insurance Corporation (FDIC) announced they are seeking...more

Sheppard Mullin Richter & Hampton LLP

Kansas City Federal Reserve Bank Explores Regulatory Risks in Gaming Ecosystems

On April 9, the Federal Reserve Bank of Kansas City published a research briefing examining how video game platforms are reshaping the digital payments landscape. As in-game purchases and platform-based transactions grow in...more

Ballard Spahr LLP

Federal Reserve Identifies Top Fair Lending Violations

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In the latest edition of its Consumer Compliance Outlook, the Federal Reserve (Fed) identified the four most significant fair lending violations that it found in examining state member banks in 2022. These are violations that...more

Nutter McClennen & Fish LLP

Nutter Bank Report: January 2025

Governor Michelle Bowman discussed the unique challenges mutual banking institutions face raising capital and the need for regulatory flexibility in the process. Governor Bowman’s remarks at the New England CEO Summit on...more

Nutter McClennen & Fish LLP

Nutter Bank Report: December 2024

CFPB Imposes $5 Cap on Overdraft Fees Charged by Large Banks - The CFPB has adopted a final rule capping overdraft fees at $5 for banks and other depository institutions with more than $10 billion in assets (covered...more

GeoDataVision

Have Regulators Already “Raised the Bar” for CRA Exams?

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When the new 2023 CRA Rule was approved by regulators FDIC Chairman Martin Gruenberg indicated one of the goals was to “raise the bar” for CRA performance ratings. Now that the final 2023 CRA performance ratings are in it...more

Mogin Law LLP

Why the Capital One-Discover Merger Makes Sense

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When federal agencies review bank mergers, the competition issues typically relate to the number and location of physical branches and the extent of any overlap in the areas served. By contrast, the proposed $35 billion...more

Ballard Spahr LLP

Bank Regulators Issue Statement on Third-Party Relationships with Financial Institutions and Publish Request for Information on...

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The federal banking regulators (The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation) issued on July 25 a lengthy joint statement...more

Troutman Pepper Locke

Federal Banking Agencies Reiterate Guidance on Managing Risks Posed By Fintech Partnerships and Other Third Party Relationships

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Last week, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies) issued a joint statement highlighting...more

Alston & Bird

CFPB and Other Federal Agencies Finally Adopt AVM Rule

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What Happened? On June 20, 2024, a group of federal regulators published a rule addressing for the use of automated valuation models (AVMs) in mortgage origination and secondary market transactions....more

Ballard Spahr LLP

Director Rohit Chopra gives the back of his hand to argument that CFPB is unlawfully funded out of losses of Federal Reserve Banks

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It took about an hour for someone on the Senate Finance Committee during its hearing today to mention the “elephant in the room” — namely, the fact that the CFPB is only allowed under Dodd-Frank to be funded out of “combined...more

Ballard Spahr LLP

A reply to Professor Sovern’s arguments as to why the Fed, notwithstanding its losses, can still lawfully fund the CFPB

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Although neither the CFPB, the Federal Reserve Board, nor the Treasury has responded to Professor Emeritus Hal Scott’s op-ed on May 20 in the Wall Street Journal, my interview with Professor Scott on our Consumer Finance...more

Cadwalader, Wickersham & Taft LLP

CFPB Finalizes Rule to Limit Credit Card Late Fees to $8

On March 5th the Consumer Financial Protection Bureau ("CFPB") announced that it had finalized its rule revisions to Regulation Z and the Official Staff Commentary regarding “Credit Card Penalty Fees.” See a redline of the...more

Ballard Spahr LLP

Durbin 2.0 Congressional Research Service Report Indicates Uncertainty of Routing Restrictions Impacts on Industry

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On December 13, 2023, the Congressional Research Service issued a report titled How the Credit Card Competition Act of 2023 Could Affect Consumers, Merchants, and Banks highlighting potential issues for Congress....more

Troutman Pepper Locke

Troutman Pepper Weekly Consumer Financial Services Newsletter - December 2023 # 2

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Cadwalader, Wickersham & Taft LLP

Vice Chair Barr Speaks on Liquidity Risk Management and Preparation for Use of Discount Window

Last Friday, Michael Barr, the Federal Reserve Board’s (“FRB”) Vice Chair for Supervision, delivered remarks to the ECB Forum on Banking Supervision in Frankfurt, Germany entitled The Importance of Effective Liquidity Risk...more

Ballard Spahr LLP

The new CRA: Understanding the final rule and its impact on large, intermediate, and small banks #1

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On October 24, 2023, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency issued a final rule amending their regulations...more

Troutman Pepper Locke

Troutman Pepper Weekly Consumer Financial Services Newsletter - November 2023 # 2

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Ballard Spahr LLP

Federal Reserve Considering Lowering Debit Card Interchange Fee Caps (UPDATED)

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As we previously blogged, the Board of Governors of the Federal Reserve (the “Board”) held an open meeting on October 25, 2023 to discuss the debit card interchange fee cap. The debit card interchange fee cap was part of the...more

Ballard Spahr LLP

OCC, Federal Reserve, and FDIC issue final Community Reinvestment Act rule

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On October 24, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation issued a final rule amending their regulations implementing the...more

Cadwalader, Wickersham & Taft LLP

Financial Kaleidoscope October 2023 - Fed Issues FAQs Clarifying That Credit-Linked Notes Can Serve as Valid Capital Relief Tools...

On September 28, the Federal Reserve Board (“FRB”) posted three new FAQs to its website regarding Regulation Q (Capital Adequacy of Bank Holding Companies, Savings and Loan Holding Companies, and State Member Banks). The FAQ...more

Ballard Spahr LLP

SCOTUS to Determine When Clock Starts under APA’s Statute of Limitations

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Last Friday, the U.S. Supreme Court agreed to decide when a right of action first accrues for an Administrative Procedure Act (APA) challenge to a final rule issued by a federal agency—when the final rule is issued or when...more

Ballard Spahr LLP

CFPB Director Rohit Chopra Addresses Mortgage Post-Crisis Reforms and Importance of Consumer Protection Regulations

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Consumer Financial Protection Bureau (CFPB) Director Rohit Chopra recently addressed The Mortgage Collaborative National Conference recounting the Congressional response to the mortgage industry crisis that began in 2008 that...more

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