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CFPB Continues its War on Fees

The CFPB recently proposed two rules on its continuing war on so-called junk fees. The first rule, proposed on January 17, target’s bank overdraft programs. Currently, financial institutions that extend overdraft loans...more

President Biden Vetoes Congressional Review Act Disapproval of CFPB’s Small Business Lending Data Collection Rule

On December 19, President Biden vetoed the joint resolution (S. J. Res. 32) the US Senate and House of Representatives passed under the Congressional Review Act that would have repealed the CFPB’s small business data...more

OIG Issues Audit Memorandum to FDIC’s Regional Service Provider Examination Program, Impacts Fintechs

On December 21, the Office of Inspector General (OIG) of the FDIC issued its audit memorandum on the FDIC’s Regional Service Provider (RSP) Examination Program. The OIG’s objective was to assess the effectiveness of the...more

Florida Introduces “True Lender” Legislation

On October 9, Florida introduced SB 146, which amends the Florida Consumer Finance Act (CFA), and joins other states that have passed laws characterizing certain nonbanks as the “true lender” of loans made through a bank...more

FDIC Issues Order Against Bank Over Fintech Partnership

On November 21, a Washington-based bank confirmed through a public filing that it entered into a consent order with the FDIC alleging that the bank engaged in unsafe or unsound banking practices, primarily related to products...more

CFPB Publishes New Report on State Community Reinvestment Laws

On November 2, the CFPB issued a new report on state Community Reinvestment Act laws. The report found that many states adopted Community Reinvestment Acts (CRAs) similar to the federal Community Reinvestment Act of 1977. The...more

Federal Reserve Issues Guidance on Supervision of “Novel Activities” by Banks, Impacts Bank-Fintech Partnerships

The Federal Reserve Board recently issued two Supervision and Regulation Letters that provide guidance on the agency’s supervision of novel activities and the process such as fintech partnerships, crypto-related activities,...more

Hsu Suggests Caution in Rollout of AI and Tokenization in Banking

On June 16, Michael Hsu, the Acting Comptroller of the Currency gave remarks at the American Bankers Association’s Risk and Compliance Conference about the risks of tokenization and AI on the banking industry. While...more

FDIC, FRB & OCC Issue Final Guidance on Risk Management for Third-Party Relationships

On June 6, the FDIC, FRB & OCC issued final interagency guidance intended to assist their respective supervised banking organizations in identifying and managing risks associated with third-party relationships and in...more

CFPB Warns of Risks Related to AI Chatbots in Banking

On June 6, the CFPB released a new report related to the adoption of chatbots by financial institutions, including those with advanced technology such as generative chatbots and others marketed as “artificial intelligence.”...more

Lawsuit Challenges CFPB Reporting Rule for Small Business Lending

On April 26, an association of Texas state banking organizations and a Texas minority depository institution filed a joint complaint against the CFPB in Texas federal court seeking to invalidate a recently finalized agency...more

Junk Fees Continue to be Focus of CFPB, Biden Administration

On March 8, the CFPB released a special edition of its Supervisory Highlights reporting on unlawful junk fees that were uncovered in a variety of servicing markets, including bank account deposits, auto loan servicing,...more

Fed Board Denies Crypto Firm’s Bid to Join Federal Reserve System

On January 27, the Federal Reserve Board (FRB) announced that it unanimously voted to deny a crypto firm’s application to become a member of the Federal Reserve System. This denial ends the crypto firm’s 27-month effort to...more

OCC Highlights Focus on Crypto and Bank-FinTech Partnerships, Anticipates Stricter Scrutiny Going Forward

On September 7, Acting Comptroller of the Currency, Michael Hsu, discussed the long-term threats to trust in banking in remarks at the TCH + BPI Annual Conference. Hsu provided updates on key priorities at the OCC, including...more

Industry Groups to CFPB: Take Back UDAAP Anti-Discrimination Policy

On June 28, the American Bankers Association, Consumer Bankers Association, Independent Community Bankers of America, and the U.S. Chamber of Commerce affirmed in a letter to CFPB Director Rohit Chopra that the CFPB should...more

CFPB Discusses Consumer Finance Data, Sets Priorities

On June 15, CFPB Deputy Director Zixta Martinez delivered a keynote address to the Consumer Federation of America’s 2022 Consumer Assembly. The Deputy Director focused on four key areas of consumer protection during her...more

OCC Acting Comptroller: Recent Crypto Events Provide a “Wake-Up Call,” “Opportunity to Reset and Recalibrate”

On May 24, the acting Comptroller of the Currency, Michael Hsu remarked at the DC Blockchain Summit 2022 about his observations on the “deep” vulnerabilities of cryptocurrency in light of the recent market volatility and...more

CFPB Director Critical of Small Bank Core Service Providers

Recently, CFPB Director Rohit Chopra spoke at a joint meeting of the CFPB’s Community Bank Advisory Council and Credit Union Advisory Council in which he expressed concerns that core service providers that many small banks...more

FDIC Warns Insured Institutions Engaging in Crypto Activities About Risks

On April 7, the FDIC issued a Financial Institution Letter (FIL-16-2022) calling on all FDIC-supervised intuitions that intend to engage in, or that are currently engaged in, any activities involving or related to crypto...more

Acting Comptroller Discusses Architecture of Stablecoins

On April 8, the acting comptroller of the currency, Michael J. Hsu, discussed many aspects of stablecoins (we previously discussed the President’s Working Group report on stablecoins and Hsu’s comments...). In his speech at...more

May 1st is Around the Corner: Bank Computer-Security Incident Notification Requirements

A few months ago, we published a post about the OCC, FDIC, and Federal Reserve Board’s final rule to improve information sharing about cyber incidents that may affect the U.S. banking system. Under the final rule, banks and...more

Virginia Approves Bill Allowing Banks to Offer Cryptocurrency Custody Services

On March 3, Virginia passed a new bill (HB 263) permitting banks in the Commonwealth to provide its customers with crypto custody services “so long as the bank has adequate protocols in place to effectively manage risks and...more

Federal Agencies Issue Interagency Statement on Special Purpose Credit Programs Under ECOA, Regulation B

On February 23, eight federal agencies including the CFPB, FDIC, OCC, Federal Reserve Board, NCUA, HUD, DOJ, and FHFA issued an interagency statement to remind creditors of the ability under the ECOA and Regulation B to...more

OCC Prevails in Challenge to “Valid When Made” Rule

On February 8, the U.S. District Court for the Northern District of California ruled against three states – California, Illinois, and New York – challenging the OCC’s rule on the “valid when made” doctrine. In 2020, the OCC...more

OCC: Bank Regulation Would Mitigate Crypto Risk

On November 3, Acting Comptroller of the Currency, Michael J. Hsu, remarked at the BritishAmerican Business Transatlantic Finance Forum 2021-2022 Executive Roundtable about the regulation of stablecoins and other...more

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