June 8, 2023 By: Stephanie Shea and Michael Flynn On June 6, 2023, the FDIC, FRB and OCC collectively issued a document entitled, “Interagency Guidance on Third-Party Relationships: Risk Management” (“2023 Guidance”). Prior...more
The Office of Information and Regulatory Affairs in the Office of Management and Budget has released the Fall 2022 Unified Agenda of Regulatory and Deregulatory Actions (Agenda) reports on the actions administrative agencies...more
1/11/2023
/ Consumer Financial Protection Bureau (CFPB) ,
Credit Cards ,
Dodd-Frank ,
Excessive Fees ,
Fair Credit Reporting Act (FCRA) ,
FDIC ,
Finance Charges ,
Insufficient Funds ,
Mortgages ,
Notice of Proposed Rulemaking (NOPR) ,
OMB ,
Overdraft Fees ,
PACE ,
Proposed Regulation ,
Regulatory Agenda ,
Small Business Loans ,
Truth in Lending Act (TILA) ,
Valuation
Under the long-recognized valid when made doctrine, if a loan was not subject to a state usury law when it was made, it does not subsequently become even if it is subsequently sold or assigned to another party. The doctrine...more
On October 29, the OCC, the Federal Reserve, the FDIC, the NCUA and the CFPB (collectively, the “agencies”) issued a Notice of Proposed Rulemaking (“NPR”) to clarify and make into a rule the prior Interagency Statement...more
On May 20, 2020, the Office of the Comptroller of the Currency (OCC) issued as new final rule updating various aspects of the requirements of the Community Reinvestment Act (CRA). The rule is effective on October 1, 2020....more
On December 12, the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) issued a proposed rule that would result in major changes to the rules applying the Community...more
12/16/2019
/ Banking Sector ,
Comment Period ,
Community Reinvestment Act ,
Depository Institutions ,
FDIC ,
Federal Reserve ,
Low Income Housing ,
OCC ,
Proposed Rules ,
Regulatory Standards ,
Small Banks
On November 19, the Federal Deposit Insurance Corporation issued a Notice of Proposed Rulemaking (FDIC Notice) setting forth a proposed rule that, if ultimately adopted, would confirm that the “valid-when-made” doctrine...more
The Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation issued a Notice of Proposed Rulemaking (Notice) that would affirm that when a national bank or savings association sells, assigns, or...more
11/19/2019
/ Assignments ,
Comment Period ,
Consumer Lenders ,
FDIC ,
Interest Rates ,
Loans ,
NPRM ,
OCC ,
Proposed Rules ,
Sale of Assets ,
Valid When Made Doctrine