News & Analysis as of

Office of the Comptroller of the Currency 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

Goodwin

2023 Year in Review: Fintech

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Welcome to the Fintech chapter of our annual report Consumer Financial Services 2023 Year in Review. Looking Ahead to 2024 - The CFPB is expected to finalize rulemaking authorizing supervision of payment application...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

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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

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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

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

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

Robins Kaplan LLP

Financial Daily Dose 10.15.2019 | Top Story: Uber lays off 350 more corporate workers in effort to control costs

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Ride-hailing giant Uber laid off 350 workers on Monday as part of an ongoing effort to pare costs that now represents 1000 jobs cut since July....more

Ballard Spahr LLP

FDIC settles Operation Choke Point lawsuit; entire lawsuit dismissed

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The FDIC has announced that it has entered into a settlement of the lawsuit filed against it and the OCC in 2014 by a trade group and several payday lenders challenging “Operation Choke Point” — a federal  enforcement...more

BakerHostetler

Financial Services 2018 Year-End Report

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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

Ballard Spahr LLP

OCC Issues Statement In Support Of Proposed Revisions To CFPB Payday Loan Rule

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Comptroller of the Currency Joseph Otting issued a statement today in support of the CFPB’s proposal that would rescind in their entirety the ability-to-repay (ATR) provisions in its final payday/auto title/high-rate...more

Goodwin

Financial Services Weekly News - February 2019

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Editor's Note - In This Issue. The Board of Governors of the Federal Reserve System (Federal Reserve) released 2019 stress test scenarios and exempted less complex banks with between $100 billion and $250 billion in assets...more

Goodwin

Financial Services Weekly Roundup - October 2018

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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

Ballard Spahr LLP

OCC small-dollar lending bulletin: one step forward but one step back?

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The OCC has issued a bulletin (2018-14) setting forth core lending principles and policies and practices for short-term, small-dollar installment lending by national banks, federal savings banks, and federal branches and...more

Vedder Price

Pay Day Lending: Here Come the Banks!

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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

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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

MoFo Reenforcement

Financial Services Report – Winter 2017

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EDITOR’S NOTE - The holidays came early for the financial services industry. First, the Senate voted to repeal the CFPB’s rule banning class waivers in arbitration agreements in consumer financial contracts. Then,...more

Goodwin

Financial Services Weekly News - November 2017 #4

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Editor's Note - A Tale of Two Agencies. On November 27, Joseph M. Otting was sworn in as the 31st Comptroller of the Currency. Mr. Otting seamlessly succeeded Keith A. Noreika, who became Acting Comptroller in May 2017...more

Nutter McClennen & Fish LLP

Nutter Bank Report, October 2017

With Vice President Mike Pence casting the tie-breaking vote, the U.S. Senate has voted to repeal the CFPB’s arbitration rule, which would have prohibited banks and other covered consumer financial service providers from...more

Goodwin

Financial Services Weekly News - October 2017 #2

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Editor's Note - CFPB Outlines Principles for Consumer-Authorized Financial Data Sharing and Aggregation. How companies share consumer data, and how much they tell consumers about their information sharing practices, has...more

Vedder Price

The CFPB’s Payday Lending Rule: An Opportunity in Disguise?

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On October 5, 2017, the Consumer Financial Protection Bureau (“CFPB”) released its nearly 1,700-page final rule for short-term loans (“Payday Lending Rule”). Notably, almost simultaneously with the CFPB’s announced Payday...more

Ballard Spahr LLP

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

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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

Morrison & Foerster LLP

CFPB Releases Final Payday Lending Rule

On October 5, 2017, the Consumer Financial Protection Bureau released its final rule for short-term loans. The nearly 1,700 page rule appears to follow the proposed short-term lending rule with several notable changes. Most...more

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