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Alston & Bird

CFPB and Other Federal Agencies Finally Adopt AVM Rule

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What Happened? On June 20, 2024, a group of federal regulators published a rule addressing for the use of automated valuation models (AVMs) in mortgage origination and secondary market transactions....more

Ballard Spahr LLP

Trade groups file lawsuit in Texas federal court challenging final OCC/FDIC/Federal Reserve Community Reinvestment Act rules

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Several national and Texas banking and business trade groups have filed a lawsuit in the U.S. District Court for the Northern District of Texas challenging the final regulations (Final Rules) implementing the Community...more

Ballard Spahr LLP

California federal district court grants summary judgment for DFPI in lawsuit challenging state’s regulations requiring...

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A California federal district court recently granted the motion for summary judgment filed by the California Department of Financial Protection and Innovation (DFPI) in the lawsuit filed by an advocacy organization seeking to...more

Orrick, Herrington & Sutcliffe LLP

NY Fed highlights an increase in unsecured loans from fintech firms in report, primarily among subprime lenders

On November 21, the Federal Reserve Bank of New York released a report on the rise and then contraction of unsecured personal loans from 2019 to 2023 for nonbank or fintech companies, and the role of alternative data and...more

Ballard Spahr LLP

The New CRA: Understanding the final rule and its impact on large, intermediate, and small banks # 3

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This is our third blog post on the final rule issued on October 24, 2023 by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency...more

Ballard Spahr LLP

The new CRA: Understanding the final rule and its impact on large, intermediate, and small banks # 2

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This is our second blog post on the final rule issued on October 24, 2023 by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency...more

Ballard Spahr LLP

CFPB/Fed/OCC increase exemption thresholds for appraisal requirement, Regs Z and M (UPDATED)

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The CFPB, Fed, and OCC have announced that they are increasing three exemption thresholds that are subject to annual inflation adjustments.  Effective January 1, 2024 through December 31, 2024, these exemption thresholds are...more

Ballard Spahr LLP

The new CRA: Understanding the final rule and its impact on large, intermediate, and small banks #1

Ballard Spahr LLP on

On October 24, 2023, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency issued a final rule amending their regulations...more

Orrick, Herrington & Sutcliffe LLP

Fed releases third quarter SLOOS survey on bank lending practices

On November 6, the Fed released its quarterly survey of Senior Loan Officer Opinion Survey (SLOOS) on bank lending practices. The report is administered to mostly domestic banks but includes some international banks....more

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - November 2023

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

Dechert LLP

Welcome to the New Normal – Funny Times Revisited

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Several weeks ago, I wrote a commentary called Funny Times in which I bemoaned the complete lack of coherent data, making the process of predicting the course of interest rates, cap rates and transactional velocity over the...more

McGlinchey Stafford

Federal Agencies Issue Joint Policy Statement for Commercial Real Estate Loan Workouts

McGlinchey Stafford on

On June 29, 2023, the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, and National Credit Union Administration (the agencies) jointly issued...more

Hudson Cook, LLP

CFPB Bites of the Month - July 2023 - Freedom, Independence, and Celebration From the CFPB

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In this month's article, we share some of our top "bites" for the prior month covered during the July 2023 webinar. Bite 10: Public Inquiry Launched into Credit Card and Loan Products for Healthcare Costs - On July 7,...more

Morrison & Foerster LLP

Regulators Replace Policy Statement on Troubled CRE Loans and Allow Short-Term Accommodations

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

Dechert LLP

Federal Regulators Adopt a New Policy Statement on Prudent Commercial Real Estate Loan Accommodations and Workouts

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The OCC, FDIC, NCUA and Fed have adopted a new Policy Statement on Prudent Commercial Real Estate Loan Accommodations and Workouts. The new policy statement updates, expands on and supersedes existing guidance from 2009,...more

Dechert LLP

Fix the CRE CLO, Mr. Market:  Tear Down This Wall!

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CRE CLO technology is languishing in the toolbox.  A combination of high interest rates, a mispriced legacy book, an anxious investor base and no real need to refresh capital until borrowers start borrowing again is largely...more

Cadwalader, Wickersham & Taft LLP

FRB Establishes Bank Term Funding Program to Aid Liquidity Availability

As we noted very briefly on Monday in our “Quick Take on a Sudden Change in the Banking Landscape,” among the various actions the government took Sunday evening to try to stabilize the banking market, the Federal Reserve...more

Brownstein Hyatt Farber Schreck

Bank Failures Spark Liquidity Injection from FHLBanks

On Monday, March 13, the Federal Home Loan Bank (FHLBank) system issued a single-day record of $88.7 billion in short-term, floating-rate notes with maturities ranging from three months to one year. The system originally...more

Goodwin

FAQ About Recent Bank Failures in the US

Goodwin on

What actions did the US government take on Sunday with respect to Silicon Valley Bank (SVB) and Signature Bank? On Sunday, March 12, the FDIC, the Federal Reserve, and the US Treasury Department announced that the US...more

Fenwick & West LLP

Silicon Valley Bank Closure: Updated Considerations Following the Creation of Silicon Valley Bridge Bank, N.A.

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Considerations relating to Silicon Valley Bank (SVB)’s closure have continued to evolve as a result of the recent announcement by the Federal Deposit Insurance Corporation (FDIC) that it has transferred all deposits—both...more

Manatt, Phelps & Phillips, LLP

Federal Reserve Establishes New Program to Enhance Bank Liquidity

On March 12, 2023, in response to concerns about the ongoing ripple effects of recent bank failures, the Federal Reserve Board established the new Bank Term Funding Program (the Program) to provide additional funding to...more

Foley Hoag LLP

Department of the Treasury, Federal Reserve, and FDIC Issue Joint Statement

Foley Hoag LLP on

On Sunday, March 12, 2023, the Treasury Department, the Federal Reserve, and the FDIC issued a joint statement indicating that there has been an agreement to roll out emergency measures to protect depositors at SVB. The...more

Fenwick & West LLP

Silicon Valley Bank Closure: Important Updates for Corporate Banking Customers

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Last Updated: Sunday, March 12, 2023, 5 p.m. PDT On Friday, March 10, 2023, Silicon Valley Bank (SVB) was closed by the California Department of Financial Protection & Innovation, The Federal Deposit Insurance Corporation...more

Morrison & Foerster LLP

FDIC Bank Receivership Frequently Asked Questions

UPDATE (3/12 PM): U.S. Treasury Uses Systemic Risk Exception to Protect Depositors of Failed Banks and the Federal Reserve Board Establishes New Emergency Facility. Following the failure of Silicon Valley Bank (SVB) on...more

K&L Gates LLP

Up Next: Lenders May Be the Next Government Focus for PPP Fraud

K&L Gates LLP on

INTRODUCTION - On 24 January 2023, the Board of Governors of the Federal Reserve System (the FRB) announced it entered into a consent order (Consent Order) with a member bank imposing an approximately US$2.3 million civil...more

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