The Federal Deposit Insurance Corporation is a United States federal agency created in 1933 in response to widespread bank failures in the 1920s and early 1930s. The FDIC's mission is to maintain... more +
The Federal Deposit Insurance Corporation is a United States federal agency created in 1933 in response to widespread bank failures in the 1920s and early 1930s. The FDIC's mission is to maintain stability and consumer confidence in the United States banking system by insuring deposits, monitoring the health of financial institutions and managing receiverships.
The New Normal: Taking Responsibility for Your Vendors
On April 30, the OCC and the FDIC announced parallel enforcement actions against a national bank and an affiliated state bank to resolve allegations that the institutions violated Section 5 of the FTC Act in their marketing...more
On April 25, the Federal Reserve Board issued a policy statement on deposit advance products. The statement came on the same day that the OCC and the FDIC proposed more formal guidance for such products....more
The Consumer Financial Protection Bureau’s civil investigative demand (“CID”) authority has recently presented significant compliance difficulties for companies that have received requests for information relating to an...more
The enactment of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act,” or “Dodd-Frank”) in 2010 was a watershed moment in the history of U.S. financial services regulation. As we move through 2013...more
A recent California case appears to contradict the general rule holding that a successor bank that has acquired a commercial loan through an FDIC receivership may owe a duty to a commercial borrower to reasonably investigate...more
On April 24, the CFPB published a white paper on payday loan and deposit advance products that claims to show those products lead to a “cycle of high-cost borrowing.” On April 25, the FDIC and the OCC proposed guidance...more
In This Issue: - FEDERAL ISSUES - STATE ISSUES - COURTS - FIRM NEWS - FIRM PUBLICATIONS - MORTGAGES - BANKING - CONSUMER FINANCE - CREDIT CARDS - E-COMMERCE - PRIVACY/DATA SECURITY -...more
Federal bank regulatory agencies have served notice that deposit advance products, sometimes known as bank “payday loans,” will soon be subject to significant new restrictions and heightened supervisory scrutiny. In...more
On Thursday, April 25, 2013, the Office of the Comptroller of the Currency (the "OCC") and the Federal Deposit Insurance Corporation (the "FDIC") proposed guidance and the Board of Governors of the Federal Reserve System (the...more
In This Issue: Leading the Past Week; Legislative Branch; and Executive Branch. Excerpt from Leading the Past Week - The past week could be best described by one word. Chaos. In the House, a scheduled...more
On April 25 the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) proposed for public comment supervisory guidance to institutions subject to their jurisdictions (i.e.,...more
Last Thursday, the Office of the Comptroller of the Currency and Federal Deposit Insurance Corporation proposed guidance on deposit advance loans. The Federal Reserve Board declined to join the OCC and FDIC and instead...more
On April 22, Judge Mariana R. Pfaelzer of the United States District Court for the Central District of California dismissed as time-barred the Federal Deposit Insurance Corporation’s (FDIC) $31 million suit against JPMorgan...more
On April 25, the FDIC issued proposed guidance relating to deposit-advance products and consumer protection risks. Comments on the proposed guidance must be received within 30 days of publication in the Federal Register....more
In This Issue: Financial Industry Developments: CFPB Proposed Clarifications on Qualified Mortgage Rules; SEC Credit Ratings Roundtable; FDIC Proposed Guidance on Deposit Advance Products; Rating Agency Developments; RMBS...more
In this issue: - NFA Amends CPO and CTA Quarterly Reporting Requirements - SDNY Imposes Second Highest Penalty Under Foreign Corrupt Practices Act - Grand Jury Indicts Swiss Lawyer and Banker in Tax...more
In This Issue: - Regulators Could Step in with Tougher Rules as Bank Profits Rise - Bill Would Force Study of Basel III Impact on Bank Capital Costs - Regulator Wants Enforcement Powers Against Bank...more
The CFPB has issued a report on payday and deposit advance loans finding that for many consumers these products lead to a cycle of indebtedness. The loans generally have three features: they are small-dollar amounts;...more
Earlier today, the CFPB released a white paper reporting on its study of 15,000,000 storefront payday loans and 100,000 accounts eligible for deposit advances (of which approximately 15% involved a deposit advance during the...more
On April 15 the Federal Reserve Board (Board) and the Federal Deposit Insurance Corporation (FDIC) announced the release of additional guidance, clarification and direction for the first group of institutions filing their...more
On April 15, the Federal Reserve Board and the FDIC issued additional guidance for the first group of institutions required to submit resolution plans pursuant to the Dodd-Frank Act. That group includes 11 institutions that...more
Traditionally, the Office of the Comptroller of the Currency (OCC) did not require a national bank seeking to engage in non-depository, trust-only activities (a “trust-only bank”) to obtain Federal Deposit Insurance...more
On April 15, the FDIC and the Fed issued a joint release which provides additional guidance, clarification and direction for the first group of 11 institutions filing their resolution plans pursuant to the Dodd-Frank Act. ...more
Second Circuit Rejects Edge Act Jurisdiction in AIG RMBS Case - On April 19, the Second Circuit ruled that a lawsuit brought by American International Group (AIG) against several Bank of America entities involving...more
In This Issue: Leading the Past Week; Legislative Branch; Executive Branch; and Upcoming Hearings. Excerpt from Leading the Past Week - It was another incredibly busy week, but obviously our thoughts and...more
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