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
Recently, the OCC released its Spring 2025 Interest Rate Risk Statistics Report detailing interest rate risk data gathered during examinations of OCC-supervised midsize and community banks and federal savings associations....more
On March 20, the OCC released a list of recent enforcement actions taken against national banks, federal savings associations, and individuals affiliated with supervised banks. Among the actions taken, the OCC issued a cease...more
Recently, the OCC released data on small business, small farm, and community development lending during 2023, compiled by the FFIEC. The 2023 data, reported by 721 lenders, revealed a slight increase in reporting institutions...more
On October 21, the OCC released its semiannual Interest Rate Risk Statistics Report, which presented data the OCC collected during examinations of midsize and community banks and federal savings associations. The report...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
The Cozen Lens- •With Super Tuesday, the State of the Union, and the release of President Biden’s FY25 budget, this past week has been a politically consequential one. This series of events mark the pivot to the general...more
The oral argument in Cantero v. Bank of America, N.A. will be heard on Tuesday, February 27 before the US Supreme Court. The Court recently granted the unopposed motion of the Solicitor General to participate in the oral...more
OCC Issues Guidance on ‘Buy Now, Pay Later’ Lending - “The guidance notes that banks should maintain underwriting, repayment terms, pricing, and safeguards that minimize adverse customer outcomes and should ensure that...more
Providers of consumer financial services that rely on federal preemption to charge customers uniform interest rates and fees on a nationwide basis are currently facing a series of legislative and litigation challenges. In...more
On November 7, 2023, the Division of Enforcement ("Division") of the United States Commodity Futures Trading Commission ("CFTC") released its annual report of the results of its enforcement efforts, announcing that it had...more
In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed a new rule to increase market transparency regarding short selling and extended the comment period for its proposed rule requiring reporting on...more
Federal Court Rejects Challenges to FDIC’s and OCC’s “Valid When Made” Rules A federal court in two separate but related cases has rejected challenges to the FDIC’s and the OCC’s respective regulations that codified the...more
A California federal district court judge rejected challenges to the OCC’s and FDIC’s Madden-fix rules brought in two separate lawsuits by state attorneys general. The OCC rule is codified at 12 C.F.R. Section 7.4001(e) and...more
A federal district judge rejected states' challenge to the Office of the Comptroller of the Currency (OCC) and Federal Deposit Insurance Corporation (FDIC) rules that the permissible interest rate for a loan is determined...more
Under the long-recognized valid when made doctrine, if a loan was not subject to a state usury law when it was made, it does not subsequently become even if it is subsequently sold or assigned to another party. The doctrine...more
On February 8, a Northern District of California judge ruled on cross motions for summary judgment filed by the states of California, Illinois, and New York (plaintiffs) and the Office of the Comptroller of the Currency and...more
More than six years after it was decided, the practical consequences of the US Court of Appeals for the Second Circuit’s Madden v. Midland Funding, LLC decision continue to diminish. The decision—which held that, under some...more
The moment has come – the moment that all have been awaiting since the summer of 2017 when the UK Financial Conduct Authority made its announcement to ultimately cease compelling reporting of the ubiquitous floating interest...more
As the year’s end approaches, the US Office of the Comptroller of the Currency (OCC), a primary US banking regulator, has published its Banking Supervision Operating Plan for 2022. As you might expect, much of the OCC’s...more
Congress has voted to overturn the Office of the Comptroller of the Currency’s (“OCC’s”) “true lender” rule under the Congressional Review Act (“CRA”), and the President has signed the resolution. Repeal of the “true lender”...more
On June 24, the House of Representatives, like the Senate on May 11, voted to overturn the Office of the Comptroller of Currency’s (OCC) “True Lender Rule” that was finalized in October 2020. The Senate initiated the process...more
As part of the ongoing transition from the London InterBank Offering Rate (LIBOR) to the Secured Overnight Financing Rate (SOFR) recommended by the Alternative Reference Rates Committee (ARRC) as an alternative rate, an...more
In Robinson v. National Collegiate Student Loan Trust 2006-2, the U.S. District Court for the District of Massachusetts accepted the validity of the “valid when made” doctrine. The District Court’s acceptance is noteworthy...more
The United Kingdom’s Financial Conduct Authority announced the future cessation and loss of representativeness of worldwide LIBOR rates. Potential Detrimental Developments - Recent Events - On Friday, March 5,...more
In recent weeks, U.S. banks have been receiving inquiries from the U.S. Federal Reserve System (the “Fed”) in connection with the banks’ current London Inter-Bank Offered Rate (“LIBOR”) exposure, plans for amendments which...more