On February 7, Acting Chairman Martin J. Gruenberg announced the Federal Deposit Insurance Corporation's (FDIC) priorities for 2022, including undertaking a comprehensive review of the process of considering and evaluating...more
In a CFPB blog post from December 9, the CFPB stated that the FDIC Board of Directors (FDIC Board) had promulgated a request for information (RFI) regarding a review of the Bank Merger Act criteria for approving bank mergers...more
The trend of fintech companies seeking or acquiring U.S. banking licenses continues to build momentum, furthering the convergence of fintech and banking. More fintech companies are applying and being approved for banking...more
In a final act of his tenure, Brian Brooks, the acting Comptroller of the Currency (OCC) on January 14 finalized a rule to ensure “fair access to banking services provided by large national banks, federal savings...more
On November 20, the Office of the Comptroller of Currency (OCC) proposed a rule aimed at ensuring fair access to bank services, capital, and credit. Citing pushes from across the political spectrum to “de-bank” industries...more
On July 20, 2020, the Office of the Comptroller of the Currency (OCC) issued its anticipated notice of proposed rulemaking on how to determine when a national bank or federal savings association (referred to collectively as a...more
On September 10, the FDIC and the OCC jointly submitted an amicus brief to the U.S. District Court for the District of Colorado in support of the appellee debt buyer in In re Rent-Rite Super Kegs West Ltd. ...more
9/19/2019
/ Amicus Briefs ,
Assignees ,
Banks ,
Commercial Bankruptcy ,
Commercial Loans ,
Debt Buyers ,
FDI Act ,
FDIC ,
Financial Services Industry ,
Interest Rates ,
Madden v Midland Funding ,
National Bank Act ,
OCC ,
Preemption ,
Valid When Made Doctrine
In October 2018 the FDIC became the latest federal financial regulator to announce plans to create an Office of Innovation, following on the heels of the OCC and the CFPB.
Originally published in Delaware Banker - Winter...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
The court explicitly acknowledged that making it difficult for banks to assign or sell their commercial property to the secondary market impedes good public policy.
On September 20, the U.S. District Court for the...more
The relationship between certain peer-to-peer or marketplace lending platforms and the banks who actually make the loans to consumers leads to the often-debated question of “Who is the true lender?” Recent court decisions...more
On July 30, 2014, the Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking (the Proposed Rule) to clarify and strengthen customer due diligence (CDD) requirements as a fifth pillar under the...more