On July 25, 2024, the Fed, the OCC and the FDIC (the “Banking Regulators”) released a “Request for Information on Bank-Fintech Arrangements Involving Banking Products and Services Distributed to Consumers and Businesses” (the...more
The banking regulators have not yet gone out on vacation, as demonstrated by this grab-bag of announcements, speeches, rules and guidance:
Acting Comptroller of the Office of the Comptroller of the Currency (OCC),...more
7/26/2024
/ Anti-Fraud Provisions ,
Banking Regulators ,
Banking Sector ,
Banks ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
NCUA ,
OCC ,
Regulatory Oversight ,
Risk Assessment ,
Risk Management
As we discussed in the fall over a series of articles (Part 1, Part 2, Part 3, and Part 4) and reported on further in January, the Consumer Financial Protection Bureau (“CFPB”) is on a mission to allow consumers to more...more
The Federal Financial Institutions Examination Council (“FFIEC”) published a statement on February 12, 2024 regarding “principles for the examination of supervised [institutions’] residential property appraisal and...more
2/23/2024
/ Appraisal ,
Banks ,
Bias ,
Consumer Financial Products ,
Discrimination ,
FFIEC ,
Financial Institutions ,
Financial Services Industry ,
FIRREA ,
Industry Examinations ,
NCUA ,
OCC ,
Property Valuation ,
Residential Property Owners ,
Supervision
As February already begins to wind down and all of us are wondering what we might have missed so far this year, here is a round-up of additional regulatory activities in financial services...more
2/23/2024
/ Bank Merger Act ,
Banks ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Debit and Credit Card Transactions ,
ECOA ,
FDIC ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Services Industry ,
New Guidance ,
NRSRO ,
OCC ,
Securities and Exchange Commission (SEC) ,
Supervisory Highlights
From January 18th to 20th, the American Bar Association’s Banking Law Committee of the Business Law Section held its winter meeting in Washington, DC. This meeting not only provides an excellent retrospective of the previous...more
On Tuesday, the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board (“FRB”) and the Office of the Comptroller of the Currency (“OCC”) (together, the “Agencies”) issued a final rule to amend and update...more
The Consumer Financial Protection Bureau ("CFPB") announced last week the publication of an Advisory Opinion regarding “Consumer Information Requests to Large Banks and Credit Unions.” The Advisory Opinion applies to “large...more
The Federal Deposit Insurance Corporation (“FDIC”) published its annual Risk Review this past Monday, providing an overview of banking conditions for 2022 through early 2023. The FDIC started providing Risk Reviews to the...more
8/21/2023
/ Annual Reports ,
Banks ,
Bitcoin ,
BSA/AML ,
Cryptocurrency ,
Digital Assets ,
FDIC ,
Financial Institutions ,
Financial Instruments ,
FinTech ,
Investment Products ,
Risk Management ,
Virtual Currency
Earlier this week, the Federal Reserve issued a Supervision and Regulation Letter regarding the “Creation of Novel Activities Supervision Program” (SR 23-7). The letter informs all banking organizations subject to supervision...more
The Federal Reserve Bank announced last week that its instant payments system, FedNow, is now live with 35 banks and credit unions, which means that “[b]anks and credit unions of all sizes can sign up and use this tool to...more
We have reported previously regarding the FDIC’s efforts to better police representations regarding deposit insurance, including when the FDIC issued an advisory regarding deposit insurance and the crypto industry last...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
2/24/2023
/ Banks ,
Cryptoassets ,
Cryptocurrency ,
FDIC ,
Federal Reserve ,
FRB ,
Joint Statements ,
Liquidity ,
Liquidity Risk Management Rule ,
OCC ,
Policy Statement
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
In many corners of financial services, Environmental, Social and Governance (“ESG”) concerns are driving innovation, SEC disclosure requirements, and even risk and compliance assessments. However, first among the prudential...more
In a lengthy, numbers-heavy blog post, the Consumer Financial Protection Bureau (“CFPB”) showed off its math skills by analyzing fees that banks collect from their retail deposit customers, with a particular focus on...more
On July 15, the Federal Deposit Insurance Corporation (“FDIC”) issued an updated Q&A regarding how companies involved in managing deposits can determine whether such deposits should be considered brokered, and/or whether they...more
The FDIC released a “Small Entity Compliance Guide” that provides a summary of its final rule allowing for the “simplification of deposit insurance,” which takes effect on April 1, 2024....more