Compliance into the Weeds: Settlement of OCC Charges for Wells Fargo Internal Auditors
Strengthening Compliance: Lessons From the OCC's Consent Order With Patriot Bank — Payments Pros – The Payments Law Podcast
2024 Payments Year in Review: CFPB and FTC Regulatory Trends – Part Four — Payments Pros – The Payments Law Podcast
Compliance Tip of the Day: TD Bank Lessons Learned – The Penalty of Growth Restrictions
Climate Risk, the emerging risk
Consumer Finance Monitor Podcast Episode: Community Reinvestment Act Reform: A Close Look at the Final Rule
Consumer Finance Monitor Podcast Episode: What the Recent Developments in Federal Preemption for National and State Banks Mean for Bank and Nonbank Consumer Financial Services Providers
Federal Banking Interagency Final Guidance on Third-Party Relationships - The Consumer Finance Podcast
Corruption, Crime and Compliance : CFPB and OCC Hit Bank of America with $250 Million Penalty for Consumer Abuse Practices
CFPB's Section 1071 Final Rule (Part 3): Potential Problem Areas – The Consumer Finance Podcast
Crypto Year in Review 2022: Federal Reserve and Central Bank Digital Currencies and FDIC/OCC Regulatory Developments - The Crypto Exchange Podcast
Crypto Enforcement Is Here, and Always Has Been
Congressional and Federal Agency Action Following Executive Order on Digital Assets Policy
Guidepost in Motion: Banking on Crypto
Compliance into the Weeds: Episode 161-OCC Guidance on 3rd Party Risk Management
Episode 127 -- Deep Dive into the OCC Enforcement Action Against Wells Fargo CEO and Senior Executives
Dealing with an Unsolicited Offer - The Bank Account
The Community Reinvestment Act (CRA): Recap and What to Expect in 2014
The New Normal: Taking Responsibility for Your Vendors
On May 8, 2025, the Conference of State Bank Supervisors (“CSBS”) asked the Office of the Comptroller of the Currency (“OCC”) to comply with Executive Orders 14129 and 14267 by reversing its regulations governing national...more
On August 27, we blogged about the Ninth Circuit unpublished panel opinion in Kivett v. Flagstar Bank issued upon remand of the case from the Supreme Court with instructions to follow the guidance of the Supreme Court...more
On July 19, we blogged about comments Acting Comptroller Hsu made before the Exchequer Club on July 17 particularly his decision to review prior OCC preemption determinations in light of the Supreme Court’s recent opinion in...more
On February 27, 2024, the U.S. Supreme Court will hear oral argument in Cantero v. Bank of America, N.A., a case involving the scope of preemption under the National Bank Act (NBA). The question before the Court is whether...more
This New Year is setting up to be a momentous one for the consumer financial services industry in the United States Supreme Court. In 2024, the Supreme Court is expected to decide four impactful cases that may hold that the...more
Last week, I moderated a live and virtual program at the American Bar Association Business Law Section 2023 Fall Meeting in Chicago. The program was entitled: “U.S. Supreme Court to Revisit Chevron Deference: What the SCOTUS...more
As previously reported, the OCC recently adopted a final rule (the “Madden fix”) designed to resolve the legal uncertainty created by the Second Circuit’s decision in Madden v. Midland Funding, which held that a non-bank that...more
Less than two months after issuing its final “Madden fix” rule, the OCC has now issued a proposed rule to address when a national bank or federal savings association should be considered the “true lender” in the context of a...more
The Office of the Comptroller of the Currency (OCC) issued a final rule on May 29 clarifying that when a national bank or national savings association sells, assigns, or otherwise transfers a loan, interest permissible before...more
On Brian Brooks’ first day as Acting Comptroller of the Currency, the OCC issued a final rule intended to resolve the legal uncertainty created by the Second Circuit’s decision in Madden v. Midland Funding. In that decision,...more
The Situation: The Office of the Comptroller of the Currency ("OCC") has appealed a decision from the Southern District of New York that concluded that the OCC lacks the authority to grant "Fintech Charters" to nondepository...more
The OCC and FDIC issued proposed rules this week intended to eliminate the uncertainty created by the Second Circuit’s decision in Madden v. Midland Funding. In that decision, the Second Circuit held that a nonbank that...more
There have been a handful of recent marketplace lending developments that indicate that the legal uncertainties in the post-Madden world are not going away anytime soon....more
The OCC and FDIC have filed a joint amicus brief in a Colorado federal district court arguing that the court should affirm the decision of a bankruptcy court holding that a non-bank loan assignee could charge the same...more
Many have believed that the national bank “fintech charter” is an ideal solution to providing marketplace consumer loans on a 50-state basis. ...more
The Office of the Comptroller of the Currency announced, in a highly anticipated decision, that it would begin to consider special-purpose charter applications from fintech entities. This move, which has been the subject of...more
The Comptroller of the Currency (“OCC”) presented a White Paper in December 2016 on Exploring Special Purpose National Bank Charters for Fintech Companies (“White Paper”). Comptroller Tom Curry noted that he had asked the OCC...more