A proposed rule published by the FDIC on March 31 would create a formal framework for the agency’s supervision and oversight of nonfinancial commercial entities that control an industrial bank. ...more
New third-party oversight guidance issued by the OCC should spur increased financial innovation at national banks. On March 5, the OCC issued OCC Bulletin 2020-10, Frequently Asked Questions to Supplement OCC Bulletin...more
3/20/2020
/ Banking Sector ,
Banks ,
FDIC ,
Financial Institutions ,
FinTech ,
New Guidance ,
Non-Bank Lenders ,
OCC ,
Risk Management ,
Third-Party ,
Third-Party Risk
Bank examinations, holding company inspections and other “supervisory events” can be a source of anxiety and dread for those who work in the banking industry.
Originally published in ABA Bank Compliance - March/April 2020....more
The need to control risks associated with using third-party technology service providers was reemphasized by the FDIC for institutions with less than $1 billion in assets in a new financial institutions letter...more
As reported in American Banker, consumer advocacy groups are concerned that financial inclusion expectations for fintechs chartered as special-purpose national banks may not perfectly mirror the requirements of the Community...more
8/16/2018
/ Community Reinvestment Act ,
Consumer Financial Products ,
Consumer Lenders ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
Innovative Technology ,
Loans ,
Low-Income Issues ,
Non-Bank Lenders ,
Regulatory Oversight ,
Regulatory Standards ,
Special Purpose National Bank Charter ,
Subprime Mortgages
In this article, we review the requirements of the Home Mortgage Disclosure Act (HMDA), highlighting key aspects of the many new and revised rules that will go into effect on January 1, 2018....more
9/27/2017
/ Banking Sector ,
Consumer Financial Protection Bureau (CFPB) ,
FFIEC ,
Financial Institutions ,
Financial Services Industry ,
Government Monitoring Information ,
HMDA ,
Mortgage Lenders ,
Mortgages ,
Regulation C ,
Reporting Requirements
The CFPB has generated acute awareness of the term “compliance management system” (CMS) through its highly publicized consent orders. Since it began issuing orders in 2011, the CFPB has invariably cited “significant...more
On June 7, the Office of the Comptroller of the Currency (OCC) issued OCC Bulletin 2017-21 (Frequently Asked Questions to Supplement Bulletin 2013-29; Third-Party Relationships: Risk Management Guidance). This is the OCC’s...more
6/29/2017
/ Consumer Financial Products ,
Consumer Lenders ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
Innovation ,
OCC ,
Online Marketplace Lending ,
Regulatory Oversight ,
Risk Management ,
Third-Party Relationships ,
Third-Party Risk
The attorney-client privilege is a rule of evidence that prevents the adverse party in a lawsuit from obtaining access to certain communications. If properly understood and wellmanaged, this privilege offers a useful tool for...more
The bulletin requires relationships between banks and marketplace lenders to be treated with the same rigor of due diligence and ongoing oversight as other relationships with third parties.
On January 24, the Office of...more
2/22/2017
/ Banking Sector ,
Banks ,
Consumer Lenders ,
Due Diligence ,
FDIC ,
Financial Institutions ,
FinTech ,
Innovation ,
Innovative Technology ,
Loans ,
Mortgages ,
OCC ,
Online Marketplace Lending ,
Risk Assessment ,
Risk Management ,
Small Business ,
Student Loans ,
Technology ,
Third-Party Relationships
During this webinar, panelists will address whether a fintech company should apply, and what is involved in obtaining the proposed fintech OCC charter....more
1/9/2017
/ Banking Sector ,
Capital Requirements ,
Consumer Financial Protection Bureau (CFPB) ,
Financial Institutions ,
FinTech ,
Fintech Charter ,
Government Investigations ,
Liquidity ,
OCC ,
Popular ,
Webinars
The compliance burdens being placed on institutions to monitor all aspects of product sales will require a substantial expansion of the types and scope of reporting that are done for product sales.
On November 28, the...more