1. FDIC Proposes Changes to Deposit Insurance Assessment Rule for CBLR Banks The FDIC has published a proposal that describes how the agency would apply the Community Bank Leverage Ratio (“CBLR”) framework previously...more
This survey reports on developments in the law relating to electronic payments. Part II addresses legal challenges to federal and state regulation of e-payments products. Part III discusses the amendment (again) of federal...more
Brokered deposits is a hot topic once again. On December 19, 2018, the Federal Deposit Insurance Corporation (the “FDIC”) published an advance notice of proposed rulemaking and request for comment on possible updates to its...more
The 2018 Winter Olympics are over. We watched two 17-year-olds win gold medals in sports that didn’t exist when we were 17. The Garlic Girls, with nicknames from their favorite breakfasts, and the U.S. men’s team won medals...more
On March 7, 2018, the Federal Deposit Insurance Corporation (FDIC) entered into a consent order with The Bancorp Bank for allegedly making inaccurate disclosures concerning the amount of transaction fees assessed on certain...more
Editor's Note - In This Issue. President Trump announced his intended nominee for Chairman of the Federal Deposit Insurance Corporation (FDIC), the Consumer Financial Protection Bureau (CFPB) proposed updates to its...more
The CFPB’s Final Rule on prepaid cards includes, in addition to the long form disclosure requirements discussed in our November 21st blog post, highly detailed requirements for providing “preacquisition” disclosures to...more
The final Prepaid Card Rule requires not only so-called “packaging” or short form disclosures prior to acquisition of the prepaid card account, but also that a long form disclosure be provided to the consumer. Whereas the...more
Financial Industry Developments - The CFPB Publishes Final Rule for Prepaid Accounts - On October 5, 2016, the Consumer Financial Protection Bureau (the "CFPB") finalized comprehensive consumer protections for...more
On March 21, the Board of Governors of the Federal Reserve, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency (OCC), and the U.S. Department of...more
Regulatory Developments - FHA Revises Loan-Level Certification Form - On March 15, the Federal Housing Administration (FHA) announced changes to its loan-level certification form. The changes resulted from concerns...more
Why it matters The Federal Deposit Insurance Corporation (FDIC) is proposing to update its Frequently Asked Questions (FAQs) on identifying, accepting, and reporting brokered deposits, and is requesting public comment on...more
Swipe Fee Settlement Yields More Litigation - Although the parties reached a $7.25 billion class action settlement of the antitrust suit brought by merchants against Visa and MasterCard over swipe fees, the case is far...more
CFPB Director Richard Cordray was among the federal financial regulators who attended a closed door meeting yesterday with President Obama. Other regulators attending the meeting included the Chairs of the Fed, FDIC and SEC....more
The interchange fee and the potential of mobile payments were the dominant payment system issues in 2012. From a landmark antitrust settlement to seemingly daily announcements of a new prepaid or mobile payment product, there...more