CFPB's Policy Statement on Abusiveness (Part 2) - The Consumer Finance Podcast
Compliance Perspectives: Changes to the Physician Self-Referral and Anti-Kickback Rules
Last week, the FCA published its long-awaited policy statement containing amendments to the FCA’s Code of Conduct (“COCON”) aimed at combatting non-financial misconduct (“NFM”). NFM can amount to a breach of FCA rules in any...more
On September 17, 2024, the Department of Justice Antitrust Division (DOJ) shut the vault doors on its 1995 Bank Merger Guidelines, leaving the 2023 Merger Guidelines as its sole authoritative statement on the topic of mergers...more
The Federal Deposit Insurance Corp. and the Office of the Comptroller of the Currency recently announced proposals to update their approaches to evaluating bank mergers and other business combinations under the Bank Merger...more
In 2023, the digital asset industry demonstrated remarkable resilience amidst significant challenges, including the dissolution of several digital asset financial services companies, numerous bank failures, and a $4.7 billion...more
The ever-growing pool of Washington alphabet soup agencies targeting the use of employee non-competes has expanded and now includes — along with the FTC and NLRB – the Federal Deposit Insurance Corporation (FDIC)....more
The Proposal clarifies the FDIC’s bank merger approval process but may prove challenging for new large bank consolidations with the FDIC as the primary regulator. On March 21, 2024, the Board of Directors of the Federal...more
Today, a divided Federal Deposit Insurance Corporation’s (FDIC) Board of Directors issued a proposed Statement of Policy (SOP) on bank merger transactions that would create a combined bank with more than $100 billion in...more
The Situation: On January 29, 2024, the Office of the Comptroller of the Currency ("OCC") requested comment on a proposed rule updating its bank merger rules and incorporating a policy statement (the "Proposal") on agency...more
On January 29, the Office of the Comptroller of the Currency (OCC) issued a notice of proposed rulemaking regarding its review of business combinations under the Bank Merger Act (BMA). Specifically, the OCC proposed: (i)...more
Earlier yesterday, the Federal Reserve Board (“FRB”), Federal Deposit Insurance Corporation (“FDIC”) and Office of the Comptroller of the Currency (“OCC”) issued a “Joint Statement on Liquidity Risks to Banking Organizations...more
Custodia Bank was denied Federal Reserve membership, while certain crypto principal activities are deemed presumptively not appropriate for member banks. On January 27, 2023, the Board of Governors of the Federal Reserve...more
The Federal Reserve Board (“FRB” or “Board”) issued two seemingly related press releases late last week. The first announced the denial of the Federal Reserve membership application by Custodia Bank, a Wyoming special purpose...more
On Friday, January 27, 2023, the Federal Reserve Board announced a new policy statement aimed at ensuring all banks with a federal supervisor receive equal treatment, regardless of their deposit insurance status. The policy...more
Federal Reserve Board (“FRB”) Chair Jerome Powell spoke at a symposium hosted by the Swedish Central Bank on Tuesday. In his speech, Chair Powell highlighted three main points: (1) that Federal Reserve monetary policy...more
In the News. On the heels of a lawsuit challenging the Office of the Comptroller of the Currency’s (OCC) recently issued Madden fix/valid when made rule, eight state attorneys general filed suit challenging a similar rule...more
In November 2016, with the election results confirmed, the banking industry was awash in hopes for a more lenient regulatory posture. To date, the industry has seen no reform. However, on March 14, 2018, the Senate passed and...more
The Small Bank Holding Company ("BHC") Policy Statement ("Policy Statement") was adopted by the Federal Reserve in 1980 to facilitate transfers of small banking organizations, including BHCs formed to assume individuals' bank...more