The Federal Reserve on Wednesday, June 5, issued an interpretation of the so-called “swaps push-out” section of the Dodd-Frank Act that corrects a drafting error that virtually everyone agrees needed to be fixed. The Federal...more
On May 23, the OCC, the FDIC, and the Federal Reserve Board published a notice to delay certain proposed changes to Call Report data collection pending further consideration of whether and how to proceed with the changes....more
On May 17, the Federal Reserve Board released an April 29, 2013 written agreement between the Federal Reserve Board, an Illinois state regulator, a foreign bank, and its U.S. bank holding company subsidiary (the Holding...more
In this issue: - CFTC Adopts Final Rules for Execution Facilities and Other Matters - FINRA Issues Interpretive Guidance on Use of Back Tested Index Data by ETPs - Mississippi District Court Defers to New...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
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
On March 21, 2013, the Office of the Comptroller of the Currency (“OCC”), the Board of Governors of the Federal Reserve System (“Federal Reserve”) and the Federal Deposit Insurance Corporation (“FDIC”) (collectively, the...more
On March 22, 2013, U.S. regulators, consisting of the Office of the Controller of the Currency (OCC), the Board of Governors of the Federal Reserve System (Federal Reserve) and the Federal Deposit Insurance Corporation (FDIC...more
On April 3, the Federal Reserve Board and the OCC jointly published a white paper on the regulators’ study of bank performance in the context of 2006 interagency guidance regarding commercial real estate lending that...more
On March 26, the Federal Reserve Board released a recent enforcement action against a bank holding company related to deficiencies in certain of its bank subsidiaries’ Bank Secrecy Act and anti-money laundering (BSA/AML)...more
On March 21, the Federal Reserve Board, the OCC, and the FDIC issued final interagency guidance to ensure institutions provide leverage lending in a safe and sound manner by: (i) identifying the institution’s risk appetite...more
On February 28, the Federal Reserve Board and the OCC jointly released amendments to their enforcement actions against multiple mortgage servicers to resolve allegations that the servicers engaged in improper mortgage...more
Many banks formed holding companies in the late 1980s and 1990s. They had various reasons for doing this. Some formed a holding company to hold subsidiaries providing nonbank activities. Some used the holding company to...more
In This Issue: *Financial Industry Developments - Amendments to Fed and OCC Foreclosure Consent Orders - Fed Proposed Rule on Systemically Important Financial Market Utilities - Rating Agency...more
On February 15, House Financial Services Committee Ranking Member Maxine Waters (D-CA) sent an amended set of requests to the Federal Reserve Board and the OCC regarding the recent agreements in principle to end the...more
On January 31, Senator Elizabeth Warren (D-MA) and Representative Elijah Cummings (D-MD), House Oversight Committee Ranking Member, sent a letter to the Federal Reserve Board and the OCC seeking documents and information...more
On January 29, the U.S. Court of Appeals for the D.C. Circuit held that the OCC and the Federal Reserve Board (FRB) improperly prohibited a bank director from participating in future banking activities of several institutions...more
In This Issue: - RECENT CASES . Dodd-Frank Challenges Under the Administrative Procedure Act and Commodity Exchange Act . Preemption . Whistleblower Protection Under the Dodd-Frank Act . Arbitration...more
On January 16, the Federal Reserve Board announced that two additional mortgage servicers subject to consent orders issued in April 2011 agreed in principle to a monetary resolution of allegations that the firms engaged in...more
As anyone who’s ever dealt with a mortgage – not to mention a foreclosure – knows, getting a straight story from mortgage servicers, the companies that handle loan modifications and foreclosures, can be next to impossible....more
On January 14, the Federal Reserve Board and the OCC issued two consent orders against a large international bank and its trust company over alleged deficiencies in its Bank Secrecy Act and Anti-Money Laundering (BSA/AML)...more
On January 18, the Fed, CFPB, FDIC, FHFA, NCUA and OCC issued a joint final rule, effective January 18, 2014, which establishes new appraisal requirements for “higher-priced mortgage loans”....more
On January 7, the OCC and the Federal Reserve Board announced that 10 of the 14 mortgage servicers subject to consent orders issued in April 2011 regarding alleged improper servicing and foreclosure practices agreed in...more
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