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Loans Consumer Financial Products Office of the Comptroller of the Currency

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

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

Troutman Pepper Locke

Troutman Pepper Weekly Consumer Financial Services Newsletter - July 2024 # 4

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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

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

Trade groups file lawsuit in Texas federal court challenging final OCC/FDIC/Federal Reserve Community Reinvestment Act rules

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Several national and Texas banking and business trade groups have filed a lawsuit in the U.S. District Court for the Northern District of Texas challenging the final regulations (Final Rules) implementing the Community...more

Troutman Pepper Locke

NY Governor Announces Plans to Regulate “Buy Now, Pay Later” Industry

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On January 2, New York Governor Kathy Hochul unveiled her 2024 consumer protection agenda, which includes plans to regulate the “buy now, pay later” (BNPL) industry. Specifically, Governor Hochul plans to propose legislation...more

Troutman Pepper Locke

OCC Issues “Buy Now, Pay Later” Guidance to Banks

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This week, the Office of the Comptroller of the Currency (OCC) issued guidance to banks on managing the risks associated with “buy now, pay later” (BNPL) lending. Specifically, the bulletin addresses BNPL loans that are...more

Ballard Spahr LLP

OCC issues guidance on managing risks associated with “buy now, pay later” lending

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The Office of the Comptroller of the Currency (OCC) has issued a bulletin (2023-37) that provides guidance on managing risks associated with “buy now, pay later” (BNPL) lending.  The BNPL loans addressed in the bulletin are...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

OCC Issues Guidance on Applicability of Legal Lending Limit to Purchased Loans

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On August 8, the Office of the Comptroller of the Currency (OCC) issued guidance on the applicability of the legal lending limit (LLL) to purchased loans. This guidance applies to community banks’ purchases of loans. In...more

Hudson Cook, LLP

CFPB Bites of the Month - July 2023 - Freedom, Independence, and Celebration From the CFPB

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In this month's article, we share some of our top "bites" for the prior month covered during the July 2023 webinar. Bite 10: Public Inquiry Launched into Credit Card and Loan Products for Healthcare Costs - On July 7,...more

Cadwalader, Wickersham & Taft LLP

Marketplace Lending Update #10: OCC’s True Lender Rule Is Repealed

On June 30, 2021, President Biden signed a joint resolution of Congress under the Congressional Review Act (“CRA”) to disapprove the OCC’s True Lender Rule. As a result, the True Lender Rule is now repealed....more

Cadwalader, Wickersham & Taft LLP

Marketplace Lending Update #9: To Thine Own Self Be True? Not Necessarily

On May 11, the Senate voted 52-47 (with three Republicans joining 49 Democrats) to pass a joint resolution under the Congressional Review Act (“CRA”) to disapprove of (i.e., rescind) the Office of Comptroller of the...more

Baker Donelson

True Lender Rule May Be Repealed

Baker Donelson on

As most financial institutions and lenders are aware, in October 2020 the Office of the Comptroller of the Currency (the OCC) issued a rule that required the identification of the "true lender" of a loan to a customer if the...more

Morgan Lewis - All Things FinReg

Members of Congress Introduce Joint CRA Resolution to Overturn the OCC’s True Lender Rule

Senator Chris Van Hollen (D-MD) introduced a Congressional Review Act (CRA) resolution of disapproval on March 26 that would invalidate the Office of the Comptroller of the Currency’s (OCC’s) true lender final rule. ...more

Ballard Spahr LLP

Ballard Spahr Submits Comment Letter to OCC in Support of Proposed True Lender Rule

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Ballard Spahr LLP has submitted a comment letter to the OCC in support of its proposed rule, “National Banks and Federal Savings Associations as Lenders” (the “Proposed Rule”)....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

Ballard Spahr LLP

Federal banking agencies issue interagency principles for small-dollar loans

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The Federal Reserve, OCC, FDIC, and NCUA have issued “Interagency Lending Principles for Offering Responsible Small-Dollar Loans.”  The agencies state that the principles are intended “to encourage supervised banks, savings...more

Ballard Spahr LLP

House Financial Services Committee: “rent-a-bank” hearing on Feb. 5; Director Kraninger to testify on Feb. 6

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On Wednesday, February 5, the House Financial Services Committee will hold the first part of a two-part hearing on “rent-a-bank” structures. The hearing is titled “Rent-A-Bank Schemes and New Debt Traps: Assessing Efforts to...more

Robins Kaplan LLP

Financial Daily Dose 1.30.2020 | Top Story: Facebook Pays $550 Million to Resolve Privacy Class Action Over Use of Facial...

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Facebook has agreed to pay $550 million to resolve a class-action lawsuit claiming that Zuck & Co.’s use of facial recognition technology violated Illinois’ biometric privacy law. Though the settlement is little more than “a...more

Robins Kaplan LLP

Financial Daily Dose 1.24.2020 | Top Story: OCC Hits Former Wells Fargo Execs With Enforcement Actions Over Sham-account Scandal

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The OCC announced yesterday that it’s bringing enforcement actions against five former Wells Fargo bank executives as part of their alleged roles in the bank’s sales practices scandal. The agency further revealed that it’s...more

Robins Kaplan LLP

Financial Daily Dose 1.9.2020 | Top Story: “Highlights” from Carlos Ghosn’s Accusatory Press Conference

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A recap of Carlos Ghosn’s big media moment on Wednesday, which was short on the escape details everyone wanted to hear and long on accusations against other execs at Nissan and Japan’s justice system....more

Robins Kaplan LLP

Financial Daily Dose 11.19.2019 | Top Story: T-Mobile Chief John Legere to Leave Company in April

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T-Mobile chief and fan-of-magenta John Legere has announced that he’ll be stepping down in April at the end of his current contract. Legere will be succeeded by Mike Sievert, the carrier’s current president and COO....more

Ballard Spahr LLP

Banking Regulators Issue Exemption from CIP Requirements for Premium Finance Loans

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The Federal Banking Agencies (“FBAs”) — collectively the Office of the Comptroller of the Currency (“OCC”); the Board of Governors of the Federal Reserve System (“Federal Reserve”); the Federal Deposit Insurance Corporation...more

A&O Shearman

US Office of the Comptroller of the Currency Encourages Banks to Meet Consumers’ Short-Term, Small-Dollar Credit Needs

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The U.S. Office of the Comptroller of the Currency issued a bulletin encouraging banks to offer responsible short-term small-dollar loans to help meet the credit needs of their customers. The OCC reminded banks, however,...more

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