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Five Federal Agencies Issue Joint Statement on Approach to Customer Due Diligence

On July 6, five federal agencies − the Board of Governors of the Federal Reserve System (“FRB”), Federal Deposit Insurance Corporation (“FDIC”), Financial Crimes Enforcement Network (“FinCEN”), National Credit Union...more

OCC Issues Its Semiannual Risk Perspective

The Office of the Comptroller of the Currency (“OCC”) issued its Semiannual Risk Perspective for Spring 2022 on June 23. This was the same day the Federal Reserve released the results of its stress test for large bank holding...more

In Depth: A Look at Federal Banking Agencies’ Proposal to Update Community Reinvestment Act Rules

As we mentioned briefly in our newsletter last week, the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board (“FRB”)  and the Office of the Comptroller of the Currency (“OCC”) (together, “The Agencies”)...more

Federal Banking Agencies Issue Interagency Proposal to Update Community Reinvestment Act Rules

On May 5, the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board (“FRB”) and the Office of the Comptroller of the Currency (“OCC”) (together, the “Agencies”) issued a notice of proposed rulemaking to...more

Federal Banking Agencies to Issue Notice of Proposed Rulemaking to Amend Uniform Rules of Practice and Procedure

On March 22, the Federal Reserve Board issued a Notice of Proposed Rulemaking (“NPR”) that will be joined by the Federal Deposit Insurance Corporation, National Credit Union Administration and the Office of the Comptroller of...more

The Development of a Bank Regulatory Framework for Fintech and Digital Assets: Reviewing U.S. Prudential Regulators’ Recent...

I.  Introduction - As we note in our companion memorandum, the Office of the Comptroller of the Currency (“OCC”) continues along its cautious course of allowing fintech and digital asset firms into the so-called...more

Marketplace Lending Update #10: OCC’s True Lender Rule Is Repealed

On June 30, 2021, President Biden signed a joint resolution of Congress under the Congressional Review Act (“CRA”) to disapprove the OCC’s True Lender Rule. As a result, the True Lender Rule is now repealed....more

Marketplace Lending Update #9: To Thine Own Self Be True? Not Necessarily

On May 11, the Senate voted 52-47 (with three Republicans joining 49 Democrats) to pass a joint resolution under the Congressional Review Act (“CRA”) to disapprove of (i.e., rescind) the Office of Comptroller of the...more

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