On January 29, the Office of the Comptroller of the Currency (OCC) issued a notice of proposed rulemaking regarding its review of business combinations under the Bank Merger Act (BMA). Specifically, the OCC proposed: (i)...more
Ballard Spahr Senior Counsel Alan S. Kaplinsky and Mark J. Levin, and David Sherwyn, Professor of Law at Cornell University’s School of Hotel Administration, today submitted lengthy comments to the Consumer Financial...more
On Wednesday, by a vote of 53-44, the Senate voted to approve S.J. 32, the resolution introduced under the Congressional Review Act (CRA) to override the CFPB’s final Section 1071 small business lending rule (1071 Rule)....more
I wrote a week or two back about my expectation that significant economic dislocation awaits us. I still think that. The morning after I published, hordes (ok, maybe not hordes) of PhD Villeins were outside my house with...more
On July 26, 2022, the Office of the Comptroller of the Currency (OCC) issued an update to its 2013 policy statement on minority depository institutions (MDIs). Changes to the policy statement include: (i) clarifying the...more
We join the nation in mourning the passing of Supreme Court Justice Ruth Bader Ginsburg. Over her 20-year career before appointment to the D.C. circuit court, Justice Ginsburg fought for equal rights in the workplace, among...more
Editor's Note - Differing Priorities? On June 14, Comptroller of the Currency Joseph M. Otting testified before the Senate Committee on Banking, Housing, and Urban Affairs, addressing his priorities for the Office of the...more
On January 20, 2017, businessman Donald J. Trump was sworn in as the 45th President of the United States following a contentious and unconventional 2016 presidential election. Republicans also successfully maintained control...more
For the first time in my memory, the Congress passed a joint resolution to disapprove a final regulation of a federal agency—in this case the CFPB and the rule was related to arbitration clauses in contracts for consumer...more
Financial Industry Developments - Agencies Issue Advanced Notice of Proposed Rulemaking on Enhanced Cyber Risk Management Standards - On October 19, 2016, the Federal Reserve Board, the Federal Deposit Insurance...more
Consistent with recent indications from CFPB and Department of Justice officials that more redlining cases would soon be coming, the CFPB and DOJ have announced a proposed consent order with Hudson City Savings Bank to settle...more
Many big cities in the United States responded to the fallout from the 2008 financial crisis by passing local laws which pressure banks to invest more in low-income neighborhoods. Between 2010 and 2013, cities such as New...more
This week, the Ferguson Commission released an analysis of the socio-economic environment following the shooting of Michael Brown that included recommendations for financially strengthening lower-income areas. The Commission,...more
The Federal Trade Commission (FTC) recently announced a settlement with a company that services auto loans for alleged violations of the Fair Credit Reporting Act (FCRA) “Furnisher Rule.” The settlement serves as a reminder...more
On August 15, 2015, the CFPB released its latest “consumer complaint snapshot.” The Bureau’s “snapshots” generally provide updated national complaint information, and further include product and geographic spotlights that...more