Evolving State Supervision: Issues Arising from State Qualification Standards and 'SAFE' Act Licensing, and Coordination with the CFPB
On Wednesday, Federal Deposit Insurance Corporation (“FDIC”) Chair Martin Gruenberg gave remarks to the Exchequer Club of Washington on the financial stability risks of nonbank financial institutions....more
Regulatory Developments - Overdraft Protection Programs: Risk Management Practices - On April 26, the OCC issued guidance in OCC Bulletin 2013-12, “Overdraft Protection Programs: Risk Management Practices,” to...more
Companies that the Financial Stability Oversight Council (FSOC) believes may be subject to FDIC receivership under the Orderly Liquidation Authority contained in Title II of the Dodd-Frank Act, and certain of their...more
The presidential election has opened the possibility of significant changes to the Dodd-Frank Act regime that has been implemented over the last six years. It remains to be seen what plans the incoming administration will...more
Campaign promises rarely turn into specific actions, but when they do, they are necessarily impacted by the dynamics of the legislative process. History suggests, however, that the policies of candidates can be a predictor of...more
On September 8, 2016, the Board of Governors of the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) issued a 107-page joint...more
Last week, the D.C. Circuit Court of Appeals reversed a D.C. District Court decision dismissing a bank’s complaint challenging the constitutionality of the CFPB based on lack of standing. The district court had concluded that...more
The Federal Reserve Board, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, and the Securities and Exchange Commission (the "SEC") issued a final rule, and the Commodity Futures...more