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Federal Agencies Announce Ramp-Up of Redlining Enforcement

The Department of Justice (DOJ) joined other federal agencies in announcing an increased focus on fair lending issues. On October 22, 2021, DOJ announced a new initiative to crack down on “modern-day” redlining. DOJ is...more

Will The True Lender Please Stand? – OCC Proposes “True Lender” Bright-Line Rule

On July 20, 2020, the Office of the Comptroller of the Currency (OCC) issued a notice of proposed rulemaking that would establish when national banks or federal savings associations (collectively, banks) are the “true lender”...more

Following Suit – FDIC Finalizes Rule Reaffirming “Valid When Made” Doctrine For State Banks

On June 25, 2020, following the OCC’s lead, the Federal Deposit Insurance Corporation’s (FDIC) board of directors voted 3-1 to finalize a rule that reaffirms the “valid when made” doctrine as applicable to loans originated by...more

Madden Put To Rest? – OCC Finalizes Rule Reaffirming “Valid When Made” Doctrine

On May 29, 2020, the Office of the Comptroller of the Currency (OCC) finalized a rule that reaffirms the “valid when made” doctrine applicable to loans originated by a national bank. According to Acting Comptroller of the...more

Attorneys General Push Against OCC’s Attempts To Codify “Valid When Made” Rule

On January 21, 2020, twenty-two State Attorneys General and the Hawaii Office of Consumer Protection submitted a comment letter to the Office of the Comptroller of the Currency (OCC) in opposition to its proposed rulemaking...more

CFPB Releases Final Payday Lending Rule

On October 5, 2017, the Consumer Financial Protection Bureau released its final rule for short-term loans. The nearly 1,700 page rule appears to follow the proposed short-term lending rule with several notable changes. Most...more

OCC Releases Semiannual Risk Perspective: Fintech is Risky?

On July 7, 2017, the Office of the Comptroller of the Currency (“OCC”) released its Semiannual Risk Perspective report (the “Report”) identifying the risks faced by national banks and federal savings associations in the ...more

OCC Issues New Third-Party Risk Management Guidance

On October 30, 2013, the Office of the Comptroller of the Currency (OCC) issued new guidance on risks presented by third-party relationships, entitled “Third-Party Relationships: Risk Management Guidance” (“2013 Bulletin”)....more

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