News & Analysis as of

Financial Services Report, Fall 2016

Editor’s Note - So much for summer! The weather is cooling, the kids are back to school, and we better not see you wearing white so long after Labor Day! For those of you having a little trouble getting back in the...more

OCC, CFPB Charge Bank With Illegal Credit Card Practices

Two regulators have forced one bank to pay $35 million for allegedly improper credit card practices—including fines owed to both the Office of the Comptroller of the Currency (OCC) and the Consumer Financial Protection Bureau...more

2017 OCC Bank Supervision Plan, House Committee Passes Dodd-Frank Reform

OCC Releases 2017 Bank Supervision Plan - The OCC’s Committee on Bank Supervision (CBS) yesterday published its Fiscal Year 2017 Bank Supervision Operating Plan and announced the following five oversight objectives...more

Financial Services Weekly News - September 2016

Editor's Note - The OCC Takes Another Step Toward a Limited Purpose FinTech Charter. On September 13, in a speech at the Marketplace Lending Policy Summit 2016, Comptroller of the Currency Thomas J. Curry discussed the...more

CFPB Levies Largest Civil Money Penalty in Agency History, Alleges “Abusive” Conduct

On September 8, 2016, the Consumer Financial Protection Bureau (CFPB or “Bureau”), the Office of the Comptroller of the Currency (OCC), and the City and County of Los Angeles entered into a Consent Order with Wells Fargo...more

10 Questions to Ask your Law Firm Vendor Management Program (Part 2)

We previously provided you five questions to determine whether your law firm vendor management program is sufficiently comprehensive. Given the attention drawn to such programs by regulators such as Office of Comptroller of...more

DoD issues MLA interpretive rule

The Department of Defense (DoD) has issued an interpretive rule to assist the industry in complying with its July 2015 final rule amending the Military Lending Act’s implementing regulation. The much-anticipated guidance was...more

CFPB, OCC, and Federal Reserve Propose Clarifications to Small Loan Exemption from HPML Appraisal Requirements

On August 4, 2016, the Consumer Financial Protection Bureau (“CFPB”), the Office of the Comptroller of the Currency (“OCC”), and the Board of Governors of the Federal Reserve System (“Federal Reserve”) (together, the...more

Trade groups seek extension of compliance date for Military Lending Act final rule

The American Bankers Association, joined by six other prominent industry trade groups, is seeking a six-month extension of the date by which depository institutions must comply with the Military Lending Act (MLA) final rule...more

Lawmakers Question Regulators on Fintech Oversight

What are federal regulators doing with regard to oversight of emerging financial technology? That question is at the heart of a letter Sens. Sherrod Brown (D-Ohio) and Jeff Merkley (D-Ore.) recently sent to the leaders of the...more

OCC and Bank Reach $3 Million Settlement Over Alleged Unfair Billing Practices

On August 25, 2016, the Office of the Comptroller of the Currency (OCC) announced that it had agreed to consent orders with a national bank based on its alleged unfair billing practices. The civil money penalty order will...more

CFPB and OCC settles claims of alleged unlawful practices for credit card add-on products

The CFPB announced that it has entered into a consent order with First National Bank of Omaha to settle charges that the bank engaged in unfair or deceptive acts or practices in connection with the marketing and sale of...more

Time to Disrupt Insurance Regulation?

Innovators are not only disrupting the financial industry but also financial regulation as regulators weigh how to monitor financial technology (fintech) innovators and their new products and services. As they begin to...more

Financial Services Weekly News - August 2016 #4

Editor's Note - Friend the Fed! As is the case every August, our federal government and regulators are hard at work, laser focused on the important issues of the day. In this regard, on August 18, the Federal Reserve...more

10 Questions to Ask your Law Firm Vendor Management Program (Part 1)

Law firms providing mortgage servicer clients default-related legal services are vendors, and financial services companies need to treat them as such. Not only that, law firms often interact directly and continuously with...more

Orrick's Financial Industry Week in Review

Agencies Issue Proposal on Method to Adjust Threshold for Exempting Small Loans from Special Appraisal Requirements - On July 22, 2016, the Consumer Financial Protection Bureau, the Federal Reserve Board and the Office...more

Translating the success of UK fintech measures to the US

The successful growth of fintech within a region depends on myriad factors, but an unquestionably material one is the regulatory environment. Regulatory regimes that foster innovation and exercise oversight in a purposeful,...more

Orrick's Financial Industry Week In Review

Agencies Issue Proposal on Method to Adjust Threshold for Exempting Small Loans from Special Appraisal Requirements - On July 22, 2016, the Consumer Financial Protection Bureau, the Federal Reserve Board and the Office...more

Agencies Issue Proposal on Method to Adjust Threshold for Exempting Small Loans from Special Appraisal Requirements

On July 22, 2016, the Consumer Financial Protection Bureau, the Federal Reserve Board and the Office of the Comptroller of the Currency issued a proposal with respect to the method for making “annual inflation adjustments to...more

Bridging the Great Divide: Collaboration Considerations for Banks and Marketplace Lenders

Marketplace lending has grown dramatically over the last several years, but it still remains a nascent industry. As it continues to expand its reach, players in the industry and the traditional banking/investment sector are...more

Key Takeaways from the OCC Forum on Supporting Financial Innovation

While the CFPB has not yet held a public event devoted to FinTech or financial innovation, the Office of the Comptroller of the Currency (OCC) recently held a Forum On Supporting Financial Innovation in the Federal Banking...more

Agencies announce submission of diversity self-assessments to OMWIs can begin

In a notice to be published in tomorrow’s Federal Register, the CFPB, OCC, Fed, FDIC, SEC, and NCUA announce that the Office of Management and Budget has approved the “information collection” contained in their “Final...more

Financial Services Weekly News - June 2016 #5

Regulatory Developments - FSOC Rescinds GE Capital's SIFI Designation - On June 29, the Financial Stability Oversight Council (FSOC) announced that it had voted unanimously to “rescind its determination that...more

The Financial Report - Volume 5, No. 11 • June 2016 (Global)

Discussion and Analysis - A few years ago, David Blass, then Chief Counsel of the SEC’s Division of Trading and Markets, created a stir when he said in a speech that private fund advisers should be concerned about some...more

Interagency Guidance Issued Regarding Deposit Reconciliation Practices

Federal banking agencies have advised financial institutions to adopt deposit reconciliation policies and practices for customer accounts, and to effectively manage the institution’s deposit reconciliation practices to comply...more

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