Climate Risk, the emerging risk
Consumer Finance Monitor Podcast Episode: Community Reinvestment Act Reform: A Close Look at the Final Rule
Consumer Finance Monitor Podcast Episode: What the Recent Developments in Federal Preemption for National and State Banks Mean for Bank and Nonbank Consumer Financial Services Providers
Federal Banking Interagency Final Guidance on Third-Party Relationships - The Consumer Finance Podcast
Corruption, Crime and Compliance : CFPB and OCC Hit Bank of America with $250 Million Penalty for Consumer Abuse Practices
CFPB's Section 1071 Final Rule (Part 3): Potential Problem Areas – The Consumer Finance Podcast
Crypto Year in Review 2022: Federal Reserve and Central Bank Digital Currencies and FDIC/OCC Regulatory Developments - The Crypto Exchange Podcast
Crypto Enforcement Is Here, and Always Has Been
Congressional and Federal Agency Action Following Executive Order on Digital Assets Policy
Guidepost in Motion: Banking on Crypto
Compliance into the Weeds: Episode 161-OCC Guidance on 3rd Party Risk Management
Episode 127 -- Deep Dive into the OCC Enforcement Action Against Wells Fargo CEO and Senior Executives
Dealing with an Unsolicited Offer - The Bank Account
The Community Reinvestment Act (CRA): Recap and What to Expect in 2014
The New Normal: Taking Responsibility for Your Vendors
The Treasury Department’s Office of the Comptroller of the Currency (“OCC”) has taken action against the former General Counsel of Michigan-based Sterling Bank and Trust in the agency’s latest action against an individual...more
The US Office of the Comptroller of the Currency (OCC) on January 29 proposed meaningful revisions to its rules and processes for reviewing proposed transactions involving national banks under the Bank Merger Act. The...more
A recent OCC report identified key issues facing the federal banking system, including increasing credit risk due to higher interest rates, increasing risk in commercial real estate lending, prolonged inflation, declining...more
In its Fall 2023 Semiannual Risk Perspective, published on December 7, the Office of the Comptroller of the Currency (“OCC”) reported on key issues facing the federal banking system. In evaluating the overall soundness of...more
To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Finance Services industry over the past week...more
But upon closer consideration, there is an interplay between a bank partner program and the Electronic Fund Transfer Act (EFTA) as implemented by Regulation E, particularly when it comes to timeframes for disputes, liable...more
Because failing to comply with the legal obligations imposed by the Bank Secrecy Act (BSA) can subject national banks or other financial institutions to significant penalties and considerable hardship, it is paramount for...more
In This Issue. The Federal Reserve Board of Governors (Federal Reserve), the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) released stress test scenarios to assess...more
In the News. The Office of the Comptroller of the Currency (OCC) finalized its “true lender” rule, which establishes that a national bank or federal savings association (bank) is the “true lender” of a loan if, as of the...more
The Office of the Comptroller of the Currency (OCC) Semiannual Risk Perspective Report highlights how the Covid-19 Pandemic has elevated operational risks for banks as they are challenged with the implementation of new...more
In the News. The Board of Governors of the Federal Reserve System (Federal Reserve) proposed rules to modernize the regulations that implement the Community Reinvestment Act (CRA); the Conference of State Bank Supervisors...more
In the News. On the heels of a lawsuit challenging the Office of the Comptroller of the Currency’s (OCC) recently issued Madden fix/valid when made rule, eight state attorneys general filed suit challenging a similar rule...more
Compliance professionals face extraordinary risks – not just for the enterprise but personal risks. CCOs should not panic or overreact when the government brings an enforcement action against a compliance officer for a...more
On December 3, 2019, four federal agencies, in consultation with state banking regulators, clarified the legal status of hemp growth and production under the Bank Secrecy Act (BSA) for banks providing financial services to...more
First Post in a Two-Part Series - Late last week, the U.S. Senate Committee on Banking, Housing, and Urban Affairs (the “Banking Committee”) met in open session to conduct a hearing on “Combating Money Laundering and Other...more
On October 23, 2018, the Office of the Comptroller of the Currency (OCC) assessed a $100 million civil money penalty against a national bank primarily known for its issuance of credit cards, for failing to comply with a 2015...more
The Federal Banking Agencies (“FBAs”) — collectively the Office of the Comptroller of the Currency (“OCC”); the Board of Governors of the Federal Reserve System (“Federal Reserve”); the Federal Deposit Insurance Corporation...more
Recently, an American bank entered into a deferred prosecution agreement requiring it to pay over US$610 million in penalties. The plea agreement was based on “impos[ing] hard caps on the number of transactions subject to AML...more
What are the top risk areas for national banks and federal savings associations? According to the Office of the Comptroller of the Currency’s (OCC) Semiannual Risk Perspective for Spring 2017, there are four: strategic,...more
In his remarks at the LendIt Conference in New York, Comptroller of the Currency Tom Curry discussed the special purpose national bank charters to be granted by the OCC to fintech companies and addressed the various...more
Editor's Note - Another Cybersecurity Proposal. On the heels of the New York State Department of Financial Services (NYDFS) issuing its proposed regulation that would require banks and insurance companies to institute...more
In our initial article announcing our top 10 considerations for financial institutions in 2016, our fifth consideration was marketplace lending. Just as the U.S. government and banking agencies have focused efforts to...more
Regulatory Developments - CFPB Now Accepting Complaints on Online Marketplace Lenders - On March 7, the Consumer Financial Protection Bureau (CFPB) announced two initiatives: it will now accept complaints from...more
Why it matters - Comptroller Thomas J. Curry underscored key 2016 supervisory concerns for his agency in a mid-December industry call discussing the OCC's latest Semiannual Risk Perspective report. His list includes the...more