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Build or Buy: New Observations Regarding a Key Choice for How to Start a “New” Bank

This is the third installment of our series evaluating the choice between starting a “new” bank through the de novo chartering process or purchasing an existing bank to implement the new business plan. Since we first wrote on...more

U.S. Senate Takes Up the RECOUP Act

The Senate Banking Committee has not taken up the previously discussed Senator Warren (D-MA) and Senator Hawley (R-MO) claw back legislation, but has instead, by a bipartisan vote, cleared to the full Senate new bipartisan...more

A Proposed New Failed Bank Clawback Act

Currently, the FDIC has a limited ability to claw back executive compensation in the event of a bank failure. An unlikely combination of U.S. Senators, including Elizabeth Warren (D-MA), Josh Hawley (R-MO), and J.D. Vance...more

FinTech Banks or Not?

Sherrod Brown, the Chairman of the Senate’s Committee on Banking, Housing, and Urban Affairs recently sent a letter to Michael Hsu, the Acting Comptroller expressing his concern over a number of national trust charters...more

PPP Round 3: New Rules, New Money, New Challenges

This week the U.S. Small Business Administration (SBA) released updated Paycheck Protection Program (PPP) interim final rules which incorporate new requirements imposed by the Economic Aid to Hard-Hit Small Businesses,...more

CDFI/MDI Community Lenders Treasury Capital Purchase Program

Congress on Monday approved a deal on a $900 billion COVID-19 economic relief package, which is expected to be signed into law within the next few days. The bill provides $12 billion in support to small lenders focused on...more

First Signs of CRA and Fair Lending Oversight Applied to the PPP

The Office of the Comptroller of the Currency (OCC) released “OCC Bulletin 2020-44” which encourages institutions to “prudently document their implementation and lending decisions” under the Small Business Administration's...more

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