News & Analysis as of

Ability-to-Repay Office of the Comptroller of the Currency

Ballard Spahr LLP

House Financial Services Committee: “rent-a-bank” hearing on Feb. 5; Director Kraninger to testify on Feb. 6

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On Wednesday, February 5, the House Financial Services Committee will hold the first part of a two-part hearing on “rent-a-bank” structures. The hearing is titled “Rent-A-Bank Schemes and New Debt Traps: Assessing Efforts to...more

Ballard Spahr LLP

Federal banking agencies and CFPB issue interagency statement on use of alternative data in credit underwriting

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The OCC, Federal Reserve Board, FDIC, NCUA and CFPB have issued an “Interagency Statement on the Use of Alternative Data in Credit Underwriting.”...more

Ballard Spahr LLP

OCC Issues Statement In Support Of Proposed Revisions To CFPB Payday Loan Rule

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Comptroller of the Currency Joseph Otting issued a statement today in support of the CFPB’s proposal that would rescind in their entirety the ability-to-repay (ATR) provisions in its final payday/auto title/high-rate...more

Nutter McClennen & Fish LLP

Nutter Bank Report, October 2017

With Vice President Mike Pence casting the tie-breaking vote, the U.S. Senate has voted to repeal the CFPB’s arbitration rule, which would have prohibited banks and other covered consumer financial service providers from...more

Vedder Price

The CFPB’s Payday Lending Rule: An Opportunity in Disguise?

Vedder Price on

On October 5, 2017, the Consumer Financial Protection Bureau (“CFPB”) released its nearly 1,700-page final rule for short-term loans (“Payday Lending Rule”). Notably, almost simultaneously with the CFPB’s announced Payday...more

Ballard Spahr LLP

OCC reacts to CFPB’s final payday loan rule by rescinding its deposit advance product guidance

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Hours after the CFPB released its final payday/auto title/high-rate installment loan rule on October 5, 2017, the OCC rescinded its guidance on deposit advance products. ...more

Morrison & Foerster LLP

CFPB Releases Final Payday Lending Rule

On October 5, 2017, the Consumer Financial Protection Bureau released its final rule for short-term loans. The nearly 1,700 page rule appears to follow the proposed short-term lending rule with several notable changes. Most...more

Ballard Spahr LLP

Guidance from the OCC to banks regarding higher loan-to-value loan programs

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On August 21, 2017, the Office of the Comptroller of the Currency (OCC) published Bulletin 2017-28 regarding higher-loan-to-value (LTV) lending programs (the “Bulletin”). Recognizing the need for further revitalization...more

Goodwin

Financial Services Weekly News - August 2016 #4

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Editor's Note - Friend the Fed! As is the case every August, our federal government and regulators are hard at work, laser focused on the important issues of the day. In this regard, on August 18, the Federal Reserve...more

Ballard Spahr LLP

FDIC Revises Examination Procedures To Incorporate TILA/RESPA Integrated Disclosures

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The FDIC has revised its interagency examination procedures to reflect the requirements of the TILA/RESPA integrated disclosures (TRID) rule. The CFPB has issued a proposal to postpone the TRID rule’s effective date from...more

Goodwin

Federal Banking Agencies Issue Interagency Statement on Supervisory Approach to Qualified Mortgage Loans

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The FDIC, OCC, NCUA and FRB issued an interagency statement on the supervisory approach to originating qualified mortgages under the CFPB’s ability-to-repay and qualified mortgage rule finalized in January 2013 and...more

Ballard Spahr LLP

Prudential Regulators Clarify Supervisory Approach Relative to CFPB Mortgage Regulation

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The Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, the National Credit Union Administration, and the Office of the Comptroller of the Currency (the “Prudential Regulators”) have...more

Orrick - Finance 20/20

Supervisory Approach for Qualified and non-Qualified Mortgage Loans

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On December 13, Fed, FDIC, NCUA and OCC issued a statement to clarify safety-and-soundness expectations in order to guide institutions engaged in residential mortgage lending as they assess the implementation of the CFPB’s...more

Goodwin

Federal Regulators Issue Statement on Fair Lending Compliance and the Ability-to-Repay and Qualified Mortgage Rules

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In response to inquiries from creditors about liability under the Equal Credit Opportunity Act’s disparate impact doctrine on originating qualified mortgages under the CFPB’s ability-to-repay provisions, the CFPB, OCC, FRB,...more

Morrison & Foerster LLP

Interagency Fair Lending Guidance: A First Step, but in the Right Direction?

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Five federal regulators, with HUD noticeably absent, issued the first interagency guidance on the much-debated intersection of fair lending enforcement and the Ability-to-Repay and Qualified Mortgage Standards Rule taking...more

Ballard Spahr LLP

CFPB joins interagency statement on qualified mortgage fair lending risks

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The CFPB was one of five federal regulators issuing an interagency statement intended to address industry concerns regarding the fair lending risks associated with compliance with the CFPB’s ability-to-repay/qualified...more

Katten Muchin Rosenman LLP

FDIC and OCC Propose Limits on Deposit Advance Loans

On April 25 the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) proposed for public comment supervisory guidance to institutions subject to their jurisdictions (i.e.,...more

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