A proposed rule published by the FDIC on March 31 would create a formal framework for the agency’s supervision and oversight of nonfinancial commercial entities that control an industrial bank. ...more
In October 2018 the FDIC became the latest federal financial regulator to announce plans to create an Office of Innovation, following on the heels of the OCC and the CFPB.
Originally published in Delaware Banker - Winter...more
Online lenders continue to be plagued by “true lender” lawsuits that challenge whether the named lender in loans made through a partnership between a nonbank lender and a regulated bank is actually an artifice in a...more
As reported in American Banker, consumer advocacy groups are concerned that financial inclusion expectations for fintechs chartered as special-purpose national banks may not perfectly mirror the requirements of the Community...more
8/16/2018
/ Community Reinvestment Act ,
Consumer Financial Products ,
Consumer Lenders ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
Innovative Technology ,
Loans ,
Low-Income Issues ,
Non-Bank Lenders ,
Regulatory Oversight ,
Regulatory Standards ,
Special Purpose National Bank Charter ,
Subprime Mortgages
When differences emerge between the activities of state banks and national banks in the U.S. dual banking system, the root cause typically is a difference between state and federal law....more
Speculation about the future of the Consumer Financial Protection Bureau (CFPB) has been ever-present since Donald Trump’s victory in the 2016 Presidential election was first announced.
Originally published in Delaware...more
3/1/2018
/ Banking Sector ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Deregulation ,
Dodd-Frank ,
Fair Lending ,
Financial Regulatory Reform ,
HMDA ,
Mission Statement ,
Policy Memorandums ,
Regulation C ,
Regulatory Agenda ,
Regulatory Oversight ,
UDAAP
On January 16, the CFPB announced plans to “reconsider” its newly minted regulation for Payday, Vehicle Title, and Certain High-Cost Installment Loans (the Payday Rule)....more
On December 5, the Government Accountability Office (GAO) essentially invalidated the CFPB’s auto lending guidance by finding that it constitutes a “rule” for purposes of the Congressional Review Act (CRA)....more
On June 7, the Office of the Comptroller of the Currency (OCC) issued OCC Bulletin 2017-21 (Frequently Asked Questions to Supplement Bulletin 2013-29; Third-Party Relationships: Risk Management Guidance). This is the OCC’s...more
6/29/2017
/ Consumer Financial Products ,
Consumer Lenders ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
Innovation ,
OCC ,
Online Marketplace Lending ,
Regulatory Oversight ,
Risk Management ,
Third-Party Relationships ,
Third-Party Risk
The compliance burdens being placed on institutions to monitor all aspects of product sales will require a substantial expansion of the types and scope of reporting that are done for product sales.
On November 28, the...more