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Call to Innovate: Is Your Bank Ready?

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

Regulatory Uncertainty at Federal Level Continues for 'Bank Model' Lending Arrangements

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

The CFPB Under New Leadership: What to Expect in 2018

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

CFPB to Reconsider Payday Loan Rule

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

Recent Congressional Review Act Developments Could Have Far-Reaching Effects

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

New OCC Bulletin on Third-Party Oversight Highlights Fintech Relationships

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

CFPB Issues Rigorous New Guidance to Financial Services Industry Regarding Sales Incentives

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

Is Your Financial Institution the Next Target of a Cyber-Attack?

In This Presentation: - Regulatory expectations for financial institutions - Risks for financial institutions - Planning to reduce risks - The Breach - Duties and responsibilities -...more

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