Consumer Finance Monitor Podcast Episode: A Close Look at the Consumer Financial Protection Bureau’s Proposal to Supervise Large Nonbank Providers of Digital Wallets and Payment Apps
In The Cross-Hairs? Protecting Your Company Against Consumer Financial Protection Bureau Investigations and Investors' Mortgage Buyback Claims
It is no secret that the Federal Reserve, the FDIC, and the OCC have zeroed in on banks' use of third parties for products, services, and other operations, the risks those arrangements may pose, and banks' responsibility to...more
Welcome to the Fintech chapter of our annual report Consumer Financial Services 2023 Year in Review. Looking Ahead to 2024 - The CFPB is expected to finalize rulemaking authorizing supervision of payment application...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 March 9, a three-judge panel of the Second Circuit heard oral argument on the question of whether the OCC can legally issue national bank charters to non-depository financial technology (fintech) firms. The case is...more
FDIC and OCC Propose CRA Modernization Rule with Opt-Out for Small Banks The FDIC and the OCC have jointly proposed amendments to modernize the agencies’ Community Reinvestment Act (“CRA”) regulations, which are intended...more
On October 25, 2018, the Conference of State Bank Supervisors (CSBS) filed suit in the U.S. District Court for the District of Columbia challenging the Office of the Comptroller of the Currency’s (OCC) creation of a new...more
In 2013, the Obama administration issued the Cole Memorandum, which called a truce between federal prosecutors and marijuana businesses operating legitimately under state law. After regime change in Washington, however, it...more
Two key federal government announcements were made on July 31, 2018 related to fintech issues. First, the U.S. Department of the Treasury (“Treasury”) issued a press release announcing a report entitled “Nonbank Financials,...more
On April 30, 2018, the United States District Court for the District of Columbia dismissed a lawsuit filed one year earlier by the Conference of State Bank Supervisors (CSBS) disputing the authority of the Office of the...more
NYSDFS Superintendent Maria T. Vullo submitted a comment letter opposing the OCC’s proposal to create a new national bank charter for FinTech companies. Vullo noted that a one-size-fits-all federal charter will not work to...more
In This Issue: - RECENT CASES ..Preemption ..CFPB Involvement in Litigation ..CFTC Regulation of Retail Commodity Transactions ..Durbin Amendment ..Appraiser Disclosure Requirements Under...more
The latest extension of the social media puzzle involves financial institutions. But, banks are not the only financial institutions governed by the alphabet soup of regulatory organizations addressing financial services (the...more
The OCC proposed to increase assessments for national banks and federal savings associations with assets of more than $40 billion. The proposal would not increase assessments for national banks and federal savings...more
Congresswoman Maxine Waters, who serves as the ranking member on the House of Representatives Committee on Financial Services, sent a letter to the Office of the Comptroller of the Currency and the Office of Mortgage...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
On December 10, 2013, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the Securities and Exchange Commission, and the Commodity...more
Today, July 9, the Federal Deposit Insurance Corporation (“FDIC”) and the Office of the Comptroller of the Currency (“OCC”) took two significant actions on the implementation of new regulatory capital requirements in the U.S....more