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Mayer Brown

The New Face of Finance Companies: What Changes with CMN Resolution No. 5,237/2025

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In one of the most relevant regulatory developments in years, the Brazilian National Monetary Council (“CMN”) issued Resolution No. 5,237, dated July 24, 2025 (“CMN Resolution 5,237/25”), establishing a new regulatory...more

Cadwalader, Wickersham & Taft LLP

Summer Reading: CRD VI, August 2025 - What Fund Finance Lenders Need To Know About CRD VI

One of the aims of the European Union’s Capital Requirements Directive VI (CRD VI) is to harmonise the banking supervisory and access framework across the EU, including in relation to the provision of core banking services....more

GeoDataVision

Wild Times for the Community Reinvestment Act

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Join top CRA experts Dr. Ken Thomas, Len Suzio and Dean Stockford for a wide ranging discussion on the Community Reinvestment Act....more

Mayer Brown

US FDIC Requests Comment on Industrial Loan Company Framework

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On July 15, 2025, the Federal Deposit Insurance Corporation (“FDIC”) requested comment on its framework for reviewing applications for deposit insurance from industrial loan companies and industrial banks (collectively,...more

A&O Shearman

PRA to review Loan to Income flow limit rule and offers interim modification by consent

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The Prudential Regulation Authority (PRA) has announced it will be reviewing the Loan to Income (LTI) flow limit requirements, following the Financial Policy Committee's (FPC) recommendation, as stated in its July financial...more

Orrick, Herrington & Sutcliffe LLP

FDIC requests information on industrial banks and loan companies

On July 15, the FDIC Board approved the publication of a request for information on how the FDIC should review filings submitted by industrial banks and industrial loan companies....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

Miles & Stockbridge P.C.

Fannie Mae Updates Multifamily Loan Documents

Fannie Mae recently announced updates to its Multifamily Loan Documents with Lender Letter (25-04). Since that time, Fannie Mae released a revised Lender Letter (25-04R) that changed the mandatory date for use of the loan...more

A&O Shearman

EBA final guidelines on ADC exposures to residential property under CRR

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The European Banking Authority (EBA) has issued its final guidelines, accompanied by a press release, on the treatment of acquisition, development and construction (ADC) exposures to residential property under Article 126a of...more

GeoDataVision

Why Do Federal Bank Regulators Create a Commercial Monopoly on Key Benchmark Data?

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Ever since the 1995 CRA rule was published bank regulators have mandated certain “community” and “market” benchmarks as the basis for rating bank performance under the CRA regulations. Most of that data is in the public...more

Mayer Brown

North Dakota Broadens Licensing Law to Include Alternative Financing

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North Dakota recently enacted legislation that amends the state’s main non-mortgage lender licensing law, the North Dakota Money Brokers Act (the “Act”), to define a “loan” to include any “alternative financing product” that...more

Mayer Brown

Georgia On (Regulators’) Mind: Significant Changes Coming to Georgia Residential Mortgage Act

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On May 14, 2025, Governor Brian Kemp signed Georgia House Bill 15 into law. House Bill 15, which will take effect on July 1, 2025, will implement several major changes to Georgia’s residential mortgage licensing law, the...more

Troutman Pepper Locke

Section 899 Implications for Foreign Banks Lending to US Borrowers through US Lending Offices

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In an earlier alert, we described the potential impact of the One Big Beautiful Bill on withholding taxes imposed on loans made by foreign banks to U.S. borrowers. ...more

Orrick, Herrington & Sutcliffe LLP

Georgia amends banking and finance laws with new act

On May 14, the Georgia General Assembly passed HB 15 revising various banking and finance provisions. The bill revises procedures for incorporators of credit unions. It also addressed licensure requirements for money...more

McGuireWoods LLP

Outbound Investment Rules and Implications on U.S. Loan Documentation

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The U.S. outbound investment security program, or Outbound Investment Rules, went into effect on Jan. 2, 2025, and financial institutions have had a few months to adjust to the new regulations....more

Sheppard Mullin Richter & Hampton LLP

Maryland Enacts Law Exempting Passive Trusts from Mortgage and Installment Loan Licensing Requirements

In January 2025, the Maryland Office of Financial Regulation (the “OFR”) issued a guidance stating that assignees of residential mortgage loans, including certain passive trusts, were required to hold a Maryland mortgage...more

GeoDataVision

Potential Improvements for CRA (Part 4b of 4)

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In the first 3 articles in this series (1, 2, 3), we identified fatal flaws in the 2023 CRA rule. In Parts 4a – 4c we propose the regulators consider potential improvements to the rule when they publish the Notice of Proposed...more

Alston & Bird

Governor Moore Signs Legislation Exempting “Passive Trusts” from Licensure in Maryland

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In a highly anticipated and welcome development, on April 22, 2025, Maryland Governor Wes Moore signed into law the Maryland Secondary Market Stability Act of 2025 (emergency measures HB 1516 and its companion SB 1026) with...more

ArentFox Schiff

The End of LIBOR: Hotel California Edition [Part IV]

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During the transition of the London InterBank Offered Rate (LIBOR) to the approved substitute benchmark in the United States, the Secured Overnight Financing Rate (SOFR), a basic question was raised as to whether the new...more

Orrick, Herrington & Sutcliffe LLP

North Dakota expands its financial data security framework, includes alternative financing providers to obtain money broker...

On April 11, North Dakota enacted HB 1127 (the “Act”), amending the regulatory framework for financial institutions within the state by establishing a new chapter focused on data security programs. The Act amends various...more

GeoDataVision

Potential Improvements for CRA (Part 4a of 4)

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In the previous 3 articles of this 4-part series I identified and explained three types of fatal flaws in the 2023 CRA rule: 1. The unreliable and sometimes misleading performance ratings based on unrealistic assessment...more

Troutman Pepper Locke

Texas Introduces Legislation to Regulate Sales-Based Commercial Financing

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Last month, the Texas legislature introduced two companion bills, S.B. No. 2677 and H.B. No. 700, to regulate sales-based commercial financing. For purposes of the proposed legislation, sales-based financing is a transaction...more

Orrick, Herrington & Sutcliffe LLP

FDIC releases January 2025 CRA evaluations

On April 4, the FDIC released an updated list of state nonmember banks evaluated for compliance with the CRA during January 2025. The CRA mandates that the FDIC assess how well banks meet the credit needs of their entire...more

Orrick, Herrington & Sutcliffe LLP

CFPB publishes 2024 HMDA Modified Loan Application Register data

On March 31, the CFPB announced it published the 2024 HMDA Modified Loan Application Register data on the FFIEC’s HMDA Platform. The data, sourced from nearly 5,000 HMDA filers, included loan-level information to assess...more

GeoDataVision

Former Senator: Bankers Can’t Be Passive About Proposed CRA Rule Rollback

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Yesterday, as I was writing this article the news broke about the regulators deciding they intend to rescind the 2023 CRA rule. My first reaction was to toss this article in the “trash” folder. But upon further reflection I...more

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