Consumer Finance Monitor Podcast Episode: Did the Supreme Court Hand the CFPB a Pyrrhic Victory?
Consumer Finance Monitor Podcast Episode: Understanding the Federal Reserve Board Proposal to Lower Interchange Fee Cap for Debit Card Transactions
Consumer Finance Monitor Podcast Episode: Community Reinvestment Act Reform: A Close Look at the Final Rule
The Future of Payments: Exploring FedNow With the Payments Professor — Payments Pros – The Payments Law Podcast
Federal Banking Interagency Final Guidance on Third-Party Relationships - The Consumer Finance Podcast
Consumer Finance Monitor Podcast Episode: What is FedNow and its Role in the U.S. Payments System?
Breaking (Down) the Debt Ceiling
Podcast: 2023 Deal Cycle - Considerations for Transactions in Uncertain Economic Times - Diagnosing Health Care
Crypto Year in Review 2022: Federal Reserve and Central Bank Digital Currencies and FDIC/OCC Regulatory Developments - The Crypto Exchange Podcast
Is the U.S. Payments System Failing Business and Consumers? A Discussion with Special Guest Dan Awrey, Professor of Law, Cornell Law School
DE Under 3: Latest Monthly Jobs Report, Unemployment & the US BLS JOLTS Report
Stablecoin Regulation in an Unstable Time: The Fed and Treasury Address a Stablecoin Regulatory Framework
Congressional and Federal Agency Action Following Executive Order on Digital Assets Policy
The Return of TALF Fund Opportunities Via COVID-19 Relief
Regulators Tackle Board Effectiveness and Overdrafts
The Community Reinvestment Act (CRA): Recap and What to Expect in 2014
It is no secret that the Federal Reserve, the FDIC, and the OCC have zeroed in on banks' use of third parties for products, services, and other operations, the risks those arrangements may pose, and banks' responsibility to...more
The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more
The American Bankers Association (ABA) has issued a new white paper, “Effective Agency Guidance: Examining Bank Regulators’ Guidance Practices,” that is intended to help agencies issue guidance that complies with legal...more
The OCC outlines safety and soundness principles and appropriate risk management processes for its regulated institutions that engage in venture lending. On November 1, 2023, the Office of the Comptroller of the Currency...more
Since the 2023 spring bank failures, the federal banking agencies have tinkered with significant bank regulations and guidance—ranging from capital, bail-in measures, and resolution planning to climate-risk stress testing,...more
Guidance for the largest US financial institutions is intended to promote climate risk management consistent with general safety and soundness practices. On October 30, 2023, the three US federal bank regulatory agencies...more
The U.S. Department of the Treasury's Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System (Board) and the Federal Deposit Insurance Corp. (FDIC) (collectively, the Agencies) on...more
A federal court has issued an order granting an injunction that delays the compliance dates for the CFPB’s final rule governing the collection of small business lending data required by Section 1071 of the Dodd-Frank Wall...more
On June 29, 2023, a new interagency Policy Statement (the Statement) was issued relating to commercial real estate (CRE) loan accommodations and workouts. The Statement is relevant to all financial institutions governed by...more
On June 6, 2023, the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, and the Office of the Comptroller of the Currency issued final joint guidance addressing bank management of...more
On June 6, 2023, the Board of Governors of the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, Agencies)...more
The Office of the Comptroller of the Currency (“OCC”) and the Federal Deposit Insurance Corporation (“FDIC”) (collectively, the “Agencies”) provided supervisory guidance this week on certain overdraft practices. Of particular...more
On March 13, the Federal Reserve Board issued FAQs on its Bank Term Funding Program, which launched March 12, to provide additional funding to eligible depository institutions in order to meet depositors’ needs. The program...more
Federal Reserve Policy Aims to Level the Playing Field for Insured and Uninsured Banks: The Federal Reserve has issued a policy statement clarifying that uninsured state member banks will be subject to the same limitations...more
Regulatory Developments - FinCEN Proposes Form of Report to Collect Beneficial Ownership Information and Application to Obtain FinCEN Identifiers - On January 17, FinCEN proposed a form of report to collect beneficial...more
Regulatory Developments - FinCEN Issues NPRM Regarding Access to Beneficial Ownership Information and Related Safeguards - On December 15, FinCEN issued a Notice of Proposed Rulemaking (NPRM) that would implement...more
On December 1, Federal Reserve Board (“FRB”) Vice Chair of Supervision Michael Barr gave a speech at the American Enterprise Institute on Bank Capital. Vice Chair Barr noted that the FRB’s holistic review of capital standards...more
The White House released a fact sheet on September 16, 2022, issuing the “First-Ever Comprehensive Framework for Responsible Development of Digital Assets” (Fact Sheet), which provides insight into the federal government’s...more
The Board of Governors of the Federal Reserve System (Federal Reserve) approved final guidelines (Guidelines) on August 15, 2022, to be used by Federal Reserve Banks (Reserve Banks) to evaluate requests to use accounts and...more
This week, the Federal Reserve Board (“FRB”) made two announcements of particular interest to the crypto-asset sector. First, on August 15, the FRB announced its final guidelines establishing factors for Reserve Banks to use...more
Last week, the Federal Reserve Board (“FRB”) announced the individual capital requirements for all large banks, effective on October 1. This announcement follows the June announcement on the results of the supervisory stress...more
On June 8, 2022, the New York State Department of Financial Services (“NYDFS”) released industry guidance applicable to U.S. dollar-backed stablecoins issued by NYDFS-regulated entities (the “Guidance”)...more
Headlines - ..New Federal Guidance Issued on Customer Due Diligence and Risk Management ..Fed Proposes Rule to Mandate LIBOR-Replacement Benchmark Rates in Contracts ..CFPB Clarifies Permissible Purposes for Furnishing,...more
Headlines - ..FDIC Proposes Substantial Increase in Deposit Insurance Assessment Rates ..Federal Reserve Releases New CECL Implementation Tool: Expected Losses ..Estimator OCC Report Highlights Risks Facing the Federal...more
On March 29, 2022, federal banking regulators issued important guidance for how banking organizations can comply with the upcoming requirement to notify regulators within 36 hours of ransomware or other disruptive...more