News & Analysis as of

Federal Reserve Proposed Rules

Venable LLP

Banking on a Nonbank Bank in 2024 - The ILC Option Revisited

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Becoming or owning an industrial loan company (or ILC)—the elusive "nonbank bank" option, as Congress coined the term in 1987— still has an allure for financial services providers that want to (1) lend on a national scale...more

WilmerHale

FinCEN’s Proposed AML/CFT Program Rule Potentially Heralds a Change in Approach

WilmerHale on

On June 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network announced long-anticipated proposed rules on anti-money laundering and countering the financing of terrorism program effectiveness;...more

Ballard Spahr LLP

Federal Agencies Finalize Reconsideration of Value Guidance

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A group of federal agencies have finalized reconsideration of value (ROV) guidance for residential real estate valuations. The agencies are the Comptroller of the Currency (OCC), Consumer Financial Protection Bureau (CFPB),...more

Kilpatrick

Bank Regulators Revive Proposed Rules on Incentive Pay

Kilpatrick on

Three federal regulators have reproposed rules that implement the requirements for bank incentive compensation programs that were included in the Dodd-Frank legislation 14 years ago. Section 956 of Dodd-Frank required the...more

Orrick, Herrington & Sutcliffe LLP

Trade associations sue OCC, FDIC, and Federal Reserve on their Proposed Rules for the CRA

On February 5, a group of trade, banking, and business associations filed a class-action complaint for injunctive relief against the OCC, Federal Reserve, and FDIC (the Agencies) for their enforcement of the new rulemaking...more

Nutter McClennen & Fish LLP

Nutter Bank Report: January 2024

OCC Requests Public Comments on Proposed Bank Merger Policy Statement and Rules The OCC has proposed a new policy to increase the transparency of the standards that the agency applies to review business combinations involving...more

Ballard Spahr LLP

Federal Reserve extends comment period for debit card interchange fee rulemaking

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The Board of Governors of the Federal Reserve (the “Board”) has announced that it is extending the comment period for its proposed changes to its debit card interchange fee rule until May 12, 2024. Comments were originally...more

Ballard Spahr LLP

CFPB/Fed/OCC increase exemption thresholds for appraisal requirement, Regs Z and M (UPDATED)

Ballard Spahr LLP on

The CFPB, Fed, and OCC have announced that they are increasing three exemption thresholds that are subject to annual inflation adjustments.  Effective January 1, 2024 through December 31, 2024, these exemption thresholds are...more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - November 2023 # 2

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Dechert LLP

Proposed Rule on Quality Control Standards for Automated Valuation Models: Comments Closed and Now What?

Dechert LLP on

The proposed rule, if adopted, would apply to mortgage originators and issuers of mortgage-backed securitizations that rely on automated valuation models (“AVMs”) to determine the value of real estate collateral. The...more

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - November 2023

The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more

Orrick, Herrington & Sutcliffe LLP

Fed seeks comment on lowering the interchange fee for debit card issuers

On October 25, the Fed announced a proposed rule that would lower the maximum interchange fee that a debit card issuer with at least $10 billion in total consolidated assets can receive for a debit card transaction and would...more

Jones Day

Federal Banking Agencies Propose Long-Term Debt Requirements for Large Banks

Jones Day on

In Short: The Situation: The Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, and Federal Deposit Insurance Corporation (collectively, the "Agencies") have proposed rules...more

Orrick, Herrington & Sutcliffe LLP

FDIC, Fed issue new rules and guidance aimed to strengthen resolution planning at large banks

On August 29, the FDIC and the Federal Reserve Board issued a joint press release inviting public comment on proposed guidance that serves to toughen requirements for non-G-SIB large bank holding companies’ resolution plans,...more

Troutman Pepper

Federal Agencies Request Comment on Proposed Rule Requiring Large Banks to Maintain Long-Term Debt

Troutman Pepper on

On August 29, the Board of Governors of the Federal Reserve System (Federal Reserve), Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller of the Currency (collectively, the agencies) issued a notice of...more

Nutter McClennen & Fish LLP

Nutter Bank Report: August 2023

A federal court has issued an order granting an injunction that delays the compliance dates for the CFPB’s final rule governing the collection of small business lending data required by Section 1071 of the Dodd-Frank Wall...more

Venable LLP

Financial Regulatory Reform Tracker - Anti-Tailoring Efforts

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Following the 2023 bank failures, the federal banking regulators (the Federal Reserve, the OCC, and the FDIC) have signaled that they are seeking to develop more stringent bank regulatory requirements for larger banking...more

Buchalter

CFPB and Federal Banking Agencies Propose Quality Control Standards on Automated Valuation Models Used in Underwriting Mortgage...

Buchalter on

On June 1, 2023, the Consumer Financial Protection Bureau along with Federal Reserve, OCC, FDIC, NCUA and FHFA (collectively, the “Agencies”) issued a Notice of Proposed Rulemaking seeking comment on rules to implement...more

Goodwin

Agencies Issue Final Guidance on Third-Party Risk Management

Goodwin on

Agencies Issue Final Guidance on Third-Party Risk Management - On June 6, the Federal Reserve, FDIC, and OCC issued final joint guidance (the Guidance) pertaining to banking organizations’ risk management of third-party...more

Nutter McClennen & Fish LLP

Nutter Bank Report: January 2023

Federal Reserve Policy Aims to Level the Playing Field for Insured and Uninsured Banks: The Federal Reserve has issued a policy statement clarifying that uninsured state member banks will be subject to the same limitations...more

Verrill

What You Need to Know About the FTC’s Proposed Non-Compete Ban

Verrill on

Today, January 5, 2023, the Federal Trade Commission (“FTC”) proposed a new rule that would ban companies from requiring non-compete agreements to be signed by employees and contractors (“Proposed Rule”). The FTC estimates...more

Cadwalader, Wickersham & Taft LLP

Federal Reserve Issues Proposed Rules under LIBOR Act

On July 19, the Federal Reserve issued a notice of proposed rulemaking (“NPR”) that would implement the Federal LIBOR Act. The NPR focuses primarily on identifying the particular version of SOFR that will apply to legacy...more

Cadwalader, Wickersham & Taft LLP

In Depth: A Look at Federal Banking Agencies’ Proposal to Update Community Reinvestment Act Rules

As we mentioned briefly in our newsletter last week, the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board (“FRB”)  and the Office of the Comptroller of the Currency (“OCC”) (together, “The Agencies”)...more

Pillsbury Winthrop Shaw Pittman LLP

Federal Banking Regulators Propose Overhaul of Community Reinvestment Act

Regulators took a first step toward modernizing CRA regulations with a joint Notice of Proposed Rulemaking. The proposed rule would add more standardized metrics for regulators’ CRA examinations and more clearly delineate...more

Bradley Arant Boult Cummings LLP

Banking Regulators Publish Proposed Rule to Update Community Reinvestment Act Regulations

On May 5, 2022, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (collectively the agencies) issued a joint notice of proposed...more

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