News & Analysis as of

Office of the Comptroller of the Currency Regulation Z

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - July 2024 # 4

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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

Jenner & Block

Client Alert: Buy Now, Pay Later: A Roadmap for Providers as Regulators Continue to Increase Scrutiny

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Point-of-sale financing arrangements payable in four or fewer interest-free installments, known as buy now, pay later (BNPL) arrangements, have soared since their initial breakthrough during the pandemic. Unlike conventional...more

Goodwin

2023 Year in Review: Fintech

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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

Hudson Cook, LLP

CFPB Bites of the Month - December 2023 - I'm Dreaming of a Winter Solstice and the CFPB

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In this month's article, we share some of our top "bites" for the prior month covered during the December 2023 webinar....more

Ballard Spahr LLP

CFPB/Fed/OCC increase exemption thresholds for appraisal requirement, Regs Z and M (UPDATED)

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The CFPB, Fed, and OCC have announced that they are increasing three exemption thresholds that are subject to annual inflation adjustments.  Effective January 1, 2024 through December 31, 2024, these exemption thresholds are...more

Orrick, Herrington & Sutcliffe LLP

OCC releases enforcement actions (UPDATE)

On May 18, the OCC released a list of recent enforcement actions taken against national banks, federal savings associations, and individuals currently and formerly affiliated with such entities. Among the enforcement actions...more

Perkins Coie

Fintech Legal Report - December 2022

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New Treasury Report Shows Fintech Industry Requires Additional Oversight To Close Gaps, Prevent Abuses, and Protect Consumers - On November 16, 2022, the U.S. Department of the Treasury (USDT), in consultation with the...more

Ballard Spahr LLP

CFPB/Fed/OCC increase exemption thresholds for appraisal requirement, Regs Z and M (UPDATED)

Ballard Spahr LLP on

The CFPB, Fed, and OCC have announced that they are increasing three exemption thresholds that are subject to annual inflation adjustments.  Effective January 1, 2023 through December 31, 2023, these exemption thresholds are...more

Nutter McClennen & Fish LLP

Nutter Bank Report: December 2021

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

Goodwin

FinCEN Issues Proposed Rule for Beneficial Ownership Information Reporting Requirements

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In This Issue. The Financial Crimes Enforcement Network (FinCEN) announced (1) a notice of proposed rulemaking for beneficial ownership information reporting requirements and (2) a regulatory process for new real estate...more

Ballard Spahr LLP

CFPB/Fed/OCC increase exemption thresholds for appraisal requirement, Regs Z and M (UPDATED)

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The CFPB, Fed, and OCC have published notices in the Federal Register announcing that they are increasing three exemption thresholds that are subject to annual inflation adjustments.  Effective January 1, 2022 through...more

Goodwin

SEC Publishes Observations From its Registered Investment Company Initiatives

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In this Issue. The U.S. Securities and Exchange Commission’s (SEC) Division of Examinations recently published a risk alert spotlighting observations from its “RIC Initiatives”; the Federal Financial Institutions Examination...more

Goodwin

Treasury Department’s FSOC Acknowledges Climate Change as Threat to Financial Stability

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In This Issue. The Treasury Department’s Financial Stability Oversight Council (FSOC) issued a report acknowledging climate change as threat to financial stability; Federal Reserve Governor Michelle Bowman advocates for...more

Nutter McClennen & Fish LLP

Nutter Bank Report: May 2021

Court Rules that Debt Collector Violated FDCPA with Communication to Dunning Vendor - A federal appellate court has recently ruled that a debt collector violated certain privacy requirements under the federal Fair Debt...more

Goodwin

SEC Finalizes Reforms Under Investment Advisers Act

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In this Issue. The Securities and Exchange Commission (SEC) finalized reforms under the Investment Advisers Act to modernize rules that govern investment adviser advertisements and payments to solicitors, and published a risk...more

Perkins Coie

Fintech Week in Review: December 2020

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FTC Alleges Mobile App’s Deposit Promises Were Deceptive - Following a May 2020, civil investigative demand, the Federal Trade Commission (FTC) filed suit against the operators of a mobile banking app, alleging that they...more

Goodwin

OCC Proposes Rules for CRA Benchmarks and Fair Access

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In the News. The Office of the Comptroller of the Currency (OCC) issued a long-awaited rule seeking comment on its proposed approach to determine the Community Reinvestment Act (CRA) evaluation measure benchmarks, retail...more

Nutter McClennen & Fish LLP

Nutter Bank Report: November 2020

Federal Banking Agencies Issue New Guidance on Managing the LIBOR Transition - The member agencies of the Federal Financial Institutions Examination Council (“FFIEC”) have issued joint guidance for banking organizations...more

Bradley Arant Boult Cummings LLP

OCC Releases Final True Lender Rule

On October 27, 2020, the OCC released its final True Lender Rule. As discussed earlier on this blog, the OCC’s rule is designed to clarify the “true lender” doctrine, a legal test utilized by courts and regulators to...more

Spilman Thomas & Battle, PLLC

All Consuming - Financial Litigation Insights: Issue 4, August 2020

Welcome! Welcome to August’s issue of All Consuming. This month, we are taking a deep dive into discharges in bankruptcy and then reviewing several top news stories in the world of consumer finance. We hope you find value...more

Goodwin

Financial Services Weekly Roundup: The OCC’s True Lender Test Embraces A Simplified Solution

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In This Issue. The Office of the Comptroller of the Currency (OCC) proposed a rule that would establish that a national bank or federal savings association is the “true lender” of a loan if, as of the date of origination, the...more

Hudson Cook, LLP

New Federal Tool for Calculating APRs

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You're probably scanning this and thinking, "math, formulas, time to skip this article." I don't blame you. For anyone who has actually looked at Regulation Z's Annual Percentage Rate formulas and felt that queasy "I'm in the...more

Nutter McClennen & Fish LLP

Bank Report: November 2019

OCC and FDIC Propose Interest Rate Fix for Loans Transferred to Non-Banks - The FDIC and OCC have separately proposed rules that would codify the “valid-when-made” doctrine and clarify that when a bank sells, assigns, or...more

Goodwin

Financial Services Weekly News Roundup: Bank Agencies Revise Applicability of Capital and Liquidity Rules

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In This Issue. The Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (Federal Reserve Board), and the Federal Deposit Insurance Corporation (FDIC) issued two final rules —...more

Goodwin

Financial Services Weekly News: Fed to Launch Real-Time Payment Service

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In This Issue. The Board of Governors of the Federal Reserve System (Federal Reserve) announced that it will launch a new round-the-clock, real-time payment and settlement service — the FedNow? Service — to support faster...more

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