Navigating Consumer Protection: The CFPB's Expanding Reach — Payments Pros – The Payments Law Podcast
Understanding Scope of Practice
Evolving State Supervision: Issues Arising from State Qualification Standards and 'SAFE' Act Licensing, and Coordination with the CFPB
Comptroller of the Currency Jonathan Gould and Acting FDIC Chairman Travis Hill recently issued public statements in support of President Trump’s executive order titled Guaranteeing Fair Banking For All Americans. The...more
Republican senators on the Banking, Housing and Urban Affairs Committee are asking banking regulators to review their process of using Matters Requiring Attention (MRA) in the bank supervisory process....more
Our Financial Services Team examines a proposed rule by the Federal Deposit Insurance Corporation (FDIC) that would revise its process for institutions to appeal material supervisory determinations....more
The FDIC is proposing to replace its Supervision Appeals Review Committee (SARC) with an independent, standalone office, known as the Office of Supervisory Appeals (OSA). Under the proposal, the OSA would be the final level...more
The Federal Reserve has announced that the agency will no longer assess reputational risk when examining banks’ risk management processes. According to the June 23 announcement, the Federal Reserve has already begun reviewing...more
The FDIC and OCC have rescinded policy statements adopted in 2024 that changed the ways each agency considered bank merger transactions and have reinstated their prior procedures for evaluating bank mergers. The FDIC on May...more
This second installment in a series of insights on bank charter considerations describes the consequences of operating through an insured depository institution charter, including capital requirements, supervision and...more
A federal court has issued an order granting an injunction that delays the compliance dates for the CFPB’s final rule governing the collection of small business lending data required by Section 1071 of the Dodd-Frank Wall...more
Regulatory Developments - Federal Reserve Announces Results From the Review of the Supervision and Regulation of SVB - On April 28, the Federal Reserve released its report analyzing SVB’s failure (Report). The Report...more
FDIC Takes Action Against False or Misleading Crypto-Related Representations - On August 19, the FDIC issued letters (the Letters) to five companies demanding that they cease and desist from making false and misleading...more
The Federal Reserve is taking measured steps to better understand the types of cryptoasset-related activities contemplated by its supervised banking organizations. On August 16, 2022, the Board of Governors of the...more
Notwithstanding the venerable status of the attorney client privilege and the important purposes it serves, the federal banking regulators and the Consumer Financial Protection Bureau have taken the position that they have...more