Consumer Protection and Safety and Soundness Perspective of Credit Union Regulation - The Consumer Finance Podcast
On July 30, 2024, the Federal Deposit Insurance Corporation (“FDIC”) Board of Directors approved a final rule that updates the FDIC’s regulations concerning Section 19 of the Federal Deposit Insurance Act, 12 U.S.C.§ 1829...more
Three federal regulators have reproposed rules that implement the requirements for bank incentive compensation programs that were included in the Dodd-Frank legislation 14 years ago. Section 956 of Dodd-Frank required the...more
On December 28, 2023, the Fed, OCC, FDIC, and NCUA published a final rule amending the Uniform Rules of Practice and Procedure to recognize the use of electronic communications and enhance the efficiency and equity of...more
This week, the Senate Banking Committee and the House Financial Services Committee held oversight hearings with leaders of the Federal Deposit Insurance Corporation (“FDIC”), Federal Reserve Board (“FRB”), the National Credit...more
The Board of Governors of the Federal Reserve System (the Board), on August 15, 2022, issued final guidelines for regional Federal Reserve Banks to use when considering applications for Federal Reserve “master...more
On April 9, 2021, the federal banking regulatory agencies (the Federal Reserve, FDIC and OCC) together with FinCEN and the National Credit Union Administration issued a joint statement addressing how risk management...more
On March 22, 2020, in response to the growing anticipation for loan modifications necessitated by the implications of the Coronavirus Disease 2019 (“COVID-19”), the Federal Reserve, Federal Deposit Insurance Corporation,...more
As the coronavirus crisis unfolds, federal and state financial services regulatory agencies have taken multiple actions impacting banks, non-bank financial service providers, and their customers. Below is a summary of those...more
FDIC and OCC Propose CRA Modernization Rule with Opt-Out for Small Banks The FDIC and the OCC have jointly proposed amendments to modernize the agencies’ Community Reinvestment Act (“CRA”) regulations, which are intended...more
The Volcker Rule Under the Trump Administration - The so-called Volcker Rule—named after Paul Volcker, a former chairman of the Federal Reserve Board—was part of the Dodd-Frank Wall Street Reform and Consumer Protection...more
In December 2016, Thomas Curry, the Comptroller of the Currency, stated that cybersecurity was the single greatest systemic threat to our financial system. He was not being hyperbolic. Cybersecurity should be on...more
The CFPB and four other agencies have issued “Interagency Guidance Regarding Deposit Reconciliation Practices.” The other agencies are the OCC, Fed, FDIC, and NCUA. The guidance is intended to set forth the agencies’...more
The National Credit Union Administration, or NCUA, became the first of six Agencies to unveil a revised rule proposal under Section 956 of the Dodd-Frank Act: prohibiting incentive-based payment arrangements that the...more
As financial institutions of all sizes continue to face unprecedented cybersecurity risk, the Federal Financial Institutions Examination Council (FFIEC) released its Cybersecurity Assessment Tool. The Assessment is...more
The Federal Financial Institutions Examination Council (FFIEC) has recently developed a new tool to help U.S. financial institutions combat the increasing volume and sophistication of cyber attacks. To blunt threats to a...more
Concurrently with a proposal from the Fed to repeal Regulation AA (12 CFR part 227), the CFPB and the federal banking agencies (Fed, OCC, FDIC and NCUA) have issued interagency guidance regarding unfair or deceptive credit...more
New York's Highest Court Will Review First Department Decision on RMBS Putback Statute of Limitations - On June 27, the Court of Appeals for the State of New York agreed to review the First Department's December 2013...more
On June 26, 2014, I participated in a panel presentation at the MBA Strategic Markets and Diversity Summit, in Washington, D.C. Stuart Ishimaru, Director of the Consumer Financial Protection Bureau’s Office of Minority and...more
The latest extension of the social media puzzle involves financial institutions. But, banks are not the only financial institutions governed by the alphabet soup of regulatory organizations addressing financial services (the...more
Council of the EU Adopts Bank Recovery and Resolution Directive - On May 6, the Council of the EU adopted at first reading the text of the Bank Recovery and Resolution Directive (BRRD). The BRRD seeks to harmonize...more
A bill introduced by Republican Senator Dan Coats would further limit the CFPB’s supervisory authority as to insured depository institutions and credit unions with total assets of $10 billion or less....more