But upon closer consideration, there is an interplay between a bank partner program and the Electronic Fund Transfer Act (EFTA) as implemented by Regulation E, particularly when it comes to timeframes for disputes, liable...more
The Board of Governors of the Federal Reserve System, Office of the Comptroller of the Currency, National Credit Union Administration, and Federal Deposit Insurance Corporation (collectively, the “Agencies”) issued a joint...more
On June 6, 2023, the Board of Governors of the Federal Reserve System, Office of the Comptroller of the Currency and Federal Deposit Insurance Corp. (collectively, the “Agencies”) issued final interagency guidance that...more
In this Issue. The Office of the Comptroller of the Currency (OCC) is seeking feedback on principles for climate-related financial risk management for large banks; the Department of Justice’s Antitrust Division is seeking...more
Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more
In this Issue. The Consumer Financial Protection Bureau (CFPB) issued a statement announcing its intention to revisit Trump-era qualified mortgage (QM) final rules; the Biden Administration announced changes to the Small...more
As financial services firms increasingly turn to artificial intelligence (AI), banking regulators warn that despite their astonishing capabilities, these tools must be relied upon with caution. Last week, the Board of...more
On December 27, 2020, the President signed into law the Consolidated Appropriations Act, 2021.Title X of Division N of that law ("Title X") contains several provisions that change the authority of the Board of Governors of...more
Publication of U.S. dollar (USD) LIBOR rates used in many financial instruments may continue longer than expected. On November 30, 2020, ICE Benchmark Administration (IBA), the administrator of LIBOR, released a statement...more
On August 3, 2020, the Federal Financial Institutions Examination Council1 (FFIEC) issued a new joint statement of principles for banks to consider while working with their loan customers as the end of COVID-19 initial loan...more
On Nov. 15, 2019, the Board of Governors of the Federal Reserve (the “Board”) released its semiannual Financial Stability Report. The report presents the Board’s current assessment of the resilience of the U.S. financial...more
On August 5, 2019, the Board of Governors of the Federal Reserve System (“Board”) proposed the development of a real-time gross settlement service (“RTGS”) called “FedNow.” The service, expected to launch in 2023 or 2024,...more
In a new letter to all financial institutions supervised by the Board of Governors of the Federal Reserve System, the Federal Reserve cautioned directors and officers about the potential limitations of director and officer...more
The Board of Governors of the Federal Reserve System has proposed amendments to Regulation EE, which implements the netting provisions of the Federal Deposit Insurance Corporation Improvement Act of 1991. The proposed...more
On May 2, 2019, the Board of Governors of the Federal Reserve System Board proposed amendments to Regulation EE, which implements the netting provisions of the Federal Deposit Insurance Corporation Improvement Act of 1991...more
The effective date of the new same-day Automated Clearing House (“ACH”) processing window (which would expand the end-of-day deadline to originate same-day transactions by two hours to 4:45 p.m. ET (1:45 p.m. PT)) has been...more