Evolving State Supervision: Issues Arising from State Qualification Standards and 'SAFE' Act Licensing, and Coordination with the CFPB
Shortly after the Supreme Court issued its 7-2 opinion in CFSA v. CFPB, holding that the funding mechanism for the CFPB created in the Dodd-Frank Act (a capped amount each year from the “combined earnings of the Federal...more
In recent weeks, and following the recent Supreme Court decision in CFPB v. CFSAA, a new debate has arisen regarding the Consumer Financial Protection Bureau (“CFPB”) funding mechanism. The crux of the debate centers around...more
On June 6, 2024, the US Department of the Treasury (Treasury) issued a request for information (RFI) on the “uses, opportunities and risks of artificial intelligence (AI) in the financial services sector.” The RFI seeks...more
What Happened? In May 2024, the Financial Stability Oversight Council (FSOC or Council) issued a Report on Nonbank Mortgage Servicing (the Report). The Report recognizes the strengths of nonbank mortgage companies (NMCs) and...more
What Happened? Following the release of the Financial Stability Oversight Council (FSOC) Report on Nonbank Mortgage Servicing, Ginnie Mae announced in APM 24-08 that certain large nonbank Ginnie Mae Issuers will now be...more
In a recent speech at Vanderbilt University, Acting Comptroller of the Currency Michael Hsu discussed his views on the potential risk of financial instability due to the merging boundaries between banking and commerce. In his...more
On February 8, the U.S. Senate Committee on Banking, Housing, and Urban Affairs held a hearing titled “The Financial Stability Oversight Council Annual Report to Congress” with testimony provided by U.S. Treasury Secretary...more
In Short - The Situation: Over the course of 2023, the Financial Stability Oversight Council ("FSOC") took steps that increase the risk of nonbank financial companies and financial activities being designated as...more
The Financial Stability Oversight Council recently released its annual report. Not surprisingly, this year’s report reviewed the banking failures in the early part of the year. In discussing the “vulnerabilities in the...more
December 14, 2023 - FSOC Issues Annual Report- The Financial Stability Oversight Council released its 2023 annual report reviewing financial market developments, describing potential emerging threats to U.S. financial...more
Editor's Note - 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,...more
In this month's article, we share some of our top "bites" for the prior month covered during the November 2023 webinar....more
A&B Abstract: On November 3, 2023 the Financial Stability Oversight Council (hereinafter “FSOC” or “Council”) unanimously approved final versions of: (1) the new Analytic Framework for Financial Stability Risk...more
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
On November 3, the Financial Stability Oversight Council (FSOC) voted unanimously to finalize the procedures for designating a nonbank financial company for Federal Reserve supervision. FSOC’s Interpretive Guidance aims to...more
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
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
A&B Abstract: On April 21, 2023 the Financial Stability Oversight Council (hereinafter “FSOC” or “Council”) issued for public comment (1) a proposed analytic framework setting forth FSOC’s approach to identifying,...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
To help you keep abreast of relevant activities, below find a breakdown of some of the biggest events at the federal and state levels to impact the Consumer Finance Services industry this past week...more
On November 10, the Consumer Financial Protection Bureau (CFPB) released a new complaint bulletin, highlighting consumer complaints it has received related to crypto-assets. The bulletin suggests that fraud, theft, hacks, and...more
The comprehensive framework, which spans multiple reports, aims to spur risk mitigation efforts and potentially a US central bank digital currency. On September 16, 2022, the White House published a fact sheet described...more
Hearing: Oversight of the U.S. Securities and Exchange Commission- September 15, 2022- The U.S. Senate Committee on Banking, Housing, and Urban Affairs held a hearing entitled, "Oversight of the U.S. Securities and...more
On March 9, 2022, the President issued an Executive Order (the “E.O.”) that articulates a high-level, wide-ranging national strategy for regulating and fostering innovation in the burgeoning digital assets space. The...more
FDIC Board Governance Dispute on Review of Bank Mergers Aired Publicly - CFPB Director Rohit Chopra on December 9 published on the CFPB’s website a blog post captioned “How Should Regulators Review Bank Mergers?” in...more