On July 27, 2023, the Board of Governors of the Federal Reserve System (FRB), the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, FBAs) issued their long-awaited...more
Is my money safe? It's a question that we haven't heard very much in over twelve years.
Most businesses and people have no experience with troubled banks and potential bank failures....more
On May 17, 2022, the FDIC board approved a final rule, effective July 5, 2022, addressing false advertising, misuse of the FDIC's name, and misrepresentations about deposit insurance, based on section 18(a)(4) of the Federal...more
Card network giants, Visa and Mastercard, are getting scrutinized by the Senate Judiciary Committee over an increase in swipe fees....more
In the last eight months, the Consumer Financial Protection Bureau (CFPB) has signaled its intent to expand its use of abusiveness theories in enforcement matters. In March, the CFPB rescinded the previous administration's...more
In July, we discussed the federal banking agencies' proposal to harmonize their respective risk management guidance. At the time, we highlighted three passages from the proposal that relate to the due diligence banking...more
Last week, the federal banking agencies—Federal Reserve Board (Board), Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC)—issued proposed interagency guidance ("Proposal") on...more