News & Analysis as of

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

Financial Services Weekly News - May 2016 #4

Breaking News - Solicitor General Files Brief in Madden v. Midland Funding - On May 24, the U.S Solicitor General (SG) filed a brief with the U.S. Supreme Court (the Court) in the matter of Madden v. Midland...more

Penny Proof for Deposits: Federal Banking Regulators Issue Interagency Guidance Regarding Deposit Reconciliation Practices

On May 18, 2016, five federal banking agencies—the Board of Governors of the Federal Reserve System (“Board”), the Consumer Financial Protection Bureau (“CFPB”), the Federal Deposit Insurance Corporation (“FDIC”), the...more

Regulators Issue New Guidance on Expectations of Deposit Reconciliations: Beware of the UDAAP Implications

In response to a recent consent order against a depository institution and several other examinations of major banks, five federal financial regulators have issued an inter-agency guidance ensuring that depository...more

Banking Agencies Issue Deposit-Reconciliation Best Practices

Five federal regulators on Wednesday – the FDIC, the Fed, CFPB, NCUA, and OCC – issued an interagency guidance applicable to all FDIC-supervised financial institutions describing expectations for effective...more

Financial Regulators Explain Their Expectations for Deposit Reconciliation

This week, the Federal Reserve Board, CFPB, FDIC, NCUA and OCC issued guidance regarding the agencies' supervisory expectations for deposit reconciliation on consumer accounts. The agencies summarized their observations on...more

CFPB issues guidance on deposit reconciliation practices

The CFPB and four other agencies have issued “Interagency Guidance Regarding Deposit Reconciliation Practices.”  The other agencies are the OCC, Fed, FDIC, and NCUA.  The guidance is intended to set forth the agencies’...more

Financial Services Weekly News - May 2016 #3

Regulatory Developments - SEC Publishes Small Entity Compliance Guide for Crowdfunding - On May 13, the Securities and Exchange Commission (SEC) published a small entity compliance guide for companies wishing to...more

OCC to hold forum on financial innovation

In his April 2016 appearance before the Senate Banking Committee, Director Cordray made clear that FinTech companies are on the CFPB’s radar screen. In particular, he indicated that while FinTech companies should not have an...more

Financial Services Weekly News - May 2016 #2

Regulatory Developments - Client Alert: CFPB Proposes Rules Prohibiting Class-Action Waivers in Arbitration Agreements - On May 5, the CFPB issued long-expected proposed rules that will drastically limit the use of...more

Financial Services Weekly News - May 2016

Regulatory Developments - CFPB Responds to Industry Concerns on Know Before You Owe Rule - On April 28, the CFPB issued a letter to banking and industry groups in response to an inquiry by the Mortgage Bankers...more

SCRA Will Continue to Receive Regulatory Scrutiny

On March 22, 2016, the U.S. House of Representatives passed the Foreclosure Relief and Extension for Servicemembers Act of 2015. This bill was signed into law by President Obama on March 31, 2016. This follows the...more

OCC Issues White Paper on "Responsible Innovation"

On March 31, 2016, the Office of the Comptroller of the Currency (OCC) issued a white paper on the growing intersection between financial services and technology. The OCC stated that "[w]hile banks continue to innovate, rapid...more

OCC Issues Paper on “Responsible Innovation”—Including Its Own Responsibilities

On March 31, the Office of the Comptroller of the Currency articulated its “vision” for responsible innovation in the federal banking system in the form of a white paper, continuing the agency’s own multi-year initiative to...more

OCC Announces Preliminary Framework on FinTech and Responsible Innovation

On March 31, 2016, the Office of the Comptroller of the Currency (“OCC”) released a white paper on financial technology innovation (“White Paper”), which lays out a preliminary framework for “responsible innovation.” The...more

OCC White Paper Promotes Framework for Supporting Responsible Innovation

Following the trend of federal agency interest in fostering (and potentially regulating) innovation in the field of financial technology (FinTech), the Office of the Comptroller of the Currency (OCC) released the white paper...more

OCC Issues FinTech White Paper Indicating Openness to 'Responsible Innovation'

On March 31, 2016, the Office of the Comptroller of the Currency (“OCC”) issued its much-anticipated white paper on the growing intersection between financial services and technology, or “FinTech.” In his prepared remarks at...more

Top 10 Financial Institution Considerations for 2016: #5 – Marketplace Lending

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

Financial Services Weekly News - March 2016 #3

Regulatory Developments - FDIC Adopts Final Rule to Increase Deposit Insurance Fund to Statutorily Required Level - On March 15, the Federal Deposit Insurance Corporation (FDIC) approved a final rule to increase the...more

Nutter Bank Report - February 2016

The Nutter Bank Report is a monthly publication of the firm's Banking and Financial Services Group. Headlines 1. CFPB Issues FCRA Compliance Guidance for Furnishers of Consumer Information 2. Joint Advisory...more

Financial Services Weekly News - March 2016 #2

Regulatory Developments - MSRB Publishes Compliance Advisory for Brokers, Dealers and Municipal Securities Dealers - The MSRB recently published its first Compliance Advisory for Brokers, Dealers and Municipal...more

Financial Services Weekly News - March 2016

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

Financial Services Report, Spring 2016

Why another law firm newsletter? Over ten years ago, Will Stern answered that question in the first Editor’s Note of the first Financial Services Report. Some things have changed since then—we no longer print and mail paper...more

A CFPB matrix for assessing civil money penalties?

The Office of the Comptroller of the Currency recently issued a revised Policies and Procedures Manual (PPM) for assessing civil money penalties (CMP). The PPM applies to CMPs assessed against all national banks, federal...more

Financial Services Weekly News - February 2015 #3

Regulatory Developments - Federal Reserve Board Repeals Regulation AA and Proposes Repeal of Regulation C - On Feb. 11, the Federal Reserve Board took steps towards transferring some of its rulemaking authority to...more

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