News & Analysis as of

Office of the Comptroller of the Currency Banking Sector Payday Loans

Nutter McClennen & Fish LLP

Nutter Bank Report: April 2025

The Federal Reserve has announced multiple decisions to rescind existing requirements for crypto-asset activities. The April 24 announcement included the rescission of a 2022 supervisory letter that required state member...more

Spilman Thomas & Battle, PLLC

Promissory Notes - Banking & Finance Insights, Issue 3

House Passes Cannabis Banking Bill - "The House passed the same bill in 2019 by a similar margin, but it stalled in what was then the GOP-controlled Senate." Why this is important: The Safe Banking Act, if passed, will...more

Morrison & Foerster LLP

Financial Services Report - Spring 2021

Can you say 0 to 60? Not cars, but pretty much everything to do with financial services. A new year, a new administration, and new challenges for providers. Prior CFPB Director Kraninger is long gone. Acting Director Uejio...more

Goodwin

CFPB Grants No-Action Letter for Proposed Small-Dollar Credit Product

Goodwin on

In the News. The Consumer Financial Protection Bureau (CFPB) granted a no-action letter (NAL) regarding a proposed small-dollar credit product and sought comment on the CFPB’s plan to study how consumers locate, comprehend...more

Goodwin

Financial Services Weekly Roundup: The OCC Proposes New Rulemaking And Changes To Address Innovation And Consumer Needs

Goodwin on

In This Issue. The Office of the Comptroller of the Currency (OCC) released an advanced notice of proposed rulemaking seeking comments on several issues related to digital technology and innovation, as well as proposed...more

Holland & Knight LLP

Stakeholders Debate Public Policy Issues Surrounding Consumer Debt in America

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A number of diverse stakeholders gathered at George Mason University (GMU) on Nov. 18, 2019, to participate in a program entitled "Consumer Debt in America: What Would Rate Caps and Student Loan Forgiveness Mean?" The debate,...more

BakerHostetler

Financial Services 2018 Year-End Report

BakerHostetler on

Welcome to the 2018 Year-End Report from BakerHostetler’s Financial Services Industry Team . We are pleased to share our analysis of some of the key developments in the financial services industry in 2018 and our expectations...more

Goodwin

Financial Services Weekly Roundup - October 2018

Goodwin on

In This Issue. The Office of the Comptroller of the Currency (OCC) released its annual supervision operating plan outlining its bank supervision priorities, issued an updated Truth in Lending Act booklet, and provided...more

Vedder Price

Pay Day Lending: Here Come the Banks!

Vedder Price on

In a recent interview, Comptroller of the Currency Joseph Otting, announced the OCC’s plan to “clarify” its support of bank-offered deposit advance products. “Deposit advance products” are typically defined as small-dollar,...more

Troutman Pepper Locke

Lifting of Longstanding OCC Consent Order May Signal Improved Environment for Bank Partnerships

Troutman Pepper Locke on

On February 14, the Office of the Comptroller of the Currency (OCC) terminated a longstanding cease-and-desist order against payday lender ACE Cash Express, Inc. ...more

Ballard Spahr LLP

OCC reacts to CFPB’s final payday loan rule by rescinding its deposit advance product guidance

Ballard Spahr LLP on

Hours after the CFPB released its final payday/auto title/high-rate installment loan rule on October 5, 2017, the OCC rescinded its guidance on deposit advance products. ...more

Clark Hill PLC

OCC Rescinds Guidance on Small-Dollar Loans: What Do Banks Do Now?

Clark Hill PLC on

Just one hour after the Consumer Financial Protection Bureau (CFPB or Bureau) issued its Final Rule for Payday, Vehicle Title and Certain High-Cost Installment Loan (CFPB Rule), the Office of the Comptroller of the Currency...more

Ballard Spahr LLP

D.C. District Court Allows Payday Lenders’ Due Process Claims To Proceed In Case Against “Operation Choke Point”

Ballard Spahr LLP on

On July 5, 2017, the U.S. District Court for the District Columbia, in the lawsuit filed in 2014 challenging “Operation Choke Point” — a federal enforcement initiative involving various agencies, including the Consumer...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

Financial Industry Developments - OCC Discusses Marketplace Lending - On September 13, 2016, Comptroller of the Currency Thomas J. Curry discussed marketplace lending's risks and associated policy questions. He...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

Financial Industry Developments - Agencies Publish Study on Banking Activities and Investments under Dodd-Frank - On September 8, 2016, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance...more

Orrick, Herrington & Sutcliffe LLP

Treasury Request for Public Input on Expanding Access to Credit through Online Marketplace Lending

On July 20, the Department of the Treasury published a Notice and Request for Information (“RFI”) seeking comment on various aspects of online marketplace lending, including – - the business models and products offered...more

Burr & Forman

Dodd-Frank News: April 2015: Dodd-Frank Wall Street Reform and Consumer Protection Act Update

Burr & Forman on

The Dodd-Frank Wall Street Reform and Consumer Protection Act was enacted as a measure to promote financial stability and protection for consumers through increased regulation of nearly every aspect of the consumer finance...more

Ballard Spahr LLP

House Republicans ask CFPB and banking agencies to disclaim “Operation Choke Point”

Ballard Spahr LLP on

Six Republican members of the House Financial Services Committee, including Chairman Jeb Hensarling, have sent identical letters to the CFPB, OCC, Fed and NCUA asking each agency to “publicly disclaim [its] past, present, and...more

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