Evolving State Supervision: Issues Arising from State Qualification Standards and 'SAFE' Act Licensing, and Coordination with the CFPB
CFPB Imposes $5 Cap on Overdraft Fees Charged by Large Banks - The CFPB has adopted a final rule capping overdraft fees at $5 for banks and other depository institutions with more than $10 billion in assets (covered...more
This periodic bulletin is designed to help companies identify important legal developments governing the use and acceptance of blockchain technology, smart contracts, and digital assets. While the use cases for blockchain...more
December 14, 2023 - FSOC Issues Annual Report- The Financial Stability Oversight Council released its 2023 annual report reviewing financial market developments, describing potential emerging threats to U.S. financial...more
Editor's Note - 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,...more
On October 24, US banking regulators, the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, and Federal Deposit Insurance Corporation (the “agencies”), issued long-awaited guidance...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
On Wednesday, Federal Deposit Insurance Corporation (“FDIC”) Chair Martin Gruenberg gave remarks to the Exchequer Club of Washington on the financial stability risks of nonbank financial institutions....more
June 17, 2023- Federal Reserve Bank of New York General Counsel Rachel Ostrander gave remarks on the panel "Bank Crisis Framework: Learning from Experience" at the Paris Meeting of the Committee on International Monetary Law...more
Regulatory Developments - Overdraft Protection Programs: Risk Management Practices - On April 26, the OCC issued guidance in OCC Bulletin 2013-12, “Overdraft Protection Programs: Risk Management Practices,” to...more
April 21, 2023- The Financial Stability Oversight Council (Council) voted unanimously to issue for public comment a proposed analytic framework for financial stability risks. The Council also voted unanimously to issue for...more
On October 3, 2022, as lawmakers in the United States continue to debate which agencies should regulate crypto-based activities, the Financial Stability Oversight Council (FSOC) released its Report on Digital Asset Financial...more
In October 2021, the Financial Stability Oversight Council (FSOC) published its inaugural Report on Climate-Related Financial Risk making over 30 recommendations to U.S. state and federal financial regulators on how best to...more
FDIC Board Governance Dispute on Review of Bank Mergers Aired Publicly - CFPB Director Rohit Chopra on December 9 published on the CFPB’s website a blog post captioned “How Should Regulators Review Bank Mergers?” in...more
On November 1, 2021, the President’s Working Group on Financial Markets (PWG) - along with the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) - published the Report on...more
The report addresses the market risks and regulatory challenges presented by stablecoins and urges Congress to act quickly. On November 1, 2021, the President’s Working Group on Financial Markets (PWG) in conjunction...more
On July 26, 2021, Neal R. Pandozzi participated as a presenter in the Strafford CLE webinar "The Phase-out of LIBOR: Navigating the Final Stages, Implementing Alternative Reference Rates and Fallback Language." The webinar...more
As spring turns to summer, climate change is on our minds. A new day, a new story about how financial institutions are addressing climate-related risks. In the past few months, six major banks—Bank of America, JPMorgan...more
In This Issue. President Biden signed an executive order addressing climate-related financial risks; the Office of the Comptroller of the Currency (OCC) finalized a rule applicable to national banks and federal savings...more
In the News. The Consumer Financial Protection Bureau (CFPB), along with the Federal Trade Commission (FTC) and more than 50 federal and state law enforcement partners, announced Operation Corrupt Collector, a nationwide law...more
The United States Senate Committee on Banking, Housing and Urban Affairs held a hearing for three individuals whose nominations to US federal financial institution regulator positions are pending...more
On June 8, 2017, the House passed H.R. 10, the Financial “CHOICE” Act with a vote of 233 to 186. Introduced on April 27, 2017, the Financial CHOICE Act proposes to amend the Dodd-Frank Act to repeal the Volcker Rule,...more
Companies that the Financial Stability Oversight Council (FSOC) believes may be subject to FDIC receivership under the Orderly Liquidation Authority contained in Title II of the Dodd-Frank Act, and certain of their...more
The presidential election has opened the possibility of significant changes to the Dodd-Frank Act regime that has been implemented over the last six years. It remains to be seen what plans the incoming administration will...more
The election of Donald J. Trump as the 45th President of the United States, along with the Republican control of the majority of both the House of Representatives and the Senate, will likely result in significant changes in...more
Campaign promises rarely turn into specific actions, but when they do, they are necessarily impacted by the dynamics of the legislative process. History suggests, however, that the policies of candidates can be a predictor of...more