News & Analysis as of

Notice of Proposed Rulemaking (NOPR) Non-Bank Lenders

Sheppard Mullin Richter & Hampton LLP

CFPB Announces It Will Not Prioritize Oversight of Repeat Offender Registry

On April 11, the CFPB announced that it will not prioritize enforcement or supervision against nonbank financial companies that miss registration deadlines under its Repeat Offender Registry. The Bureau also stated that it is...more

Perkins Coie

FDIC’s Proposed Changes to Custodial Deposit Accounts: Practical Implications for Fintechs and Their Banks

Perkins Coie on

The Federal Deposit Insurance Corporation (FDIC) issued a Notice of Proposed Rulemaking (the Proposal) on September 17, 2024, that seeks to strengthen recordkeeping for bank deposits held by nonbank companies on behalf of...more

Seward & Kissel LLP

Proposed FDIC Rule Would Impose Additional Deposit Insurance Disclosure Obligations on Banks and Non-Banks

Seward & Kissel LLP on

The Federal Deposit Insurance Corporation (“FDIC”) published for comment in December 2022 a notice of proposed rulemaking (12 CFR Part 328) (“Proposed Rule”) that would apply to all FDIC-insured institutions and impose new...more

Foley & Lardner LLP

CFPB's Notice of Proposed Rulemaking

Foley & Lardner LLP on

On January 11, 2023, the Consumer Financial Protection Bureau (CFPB) issued a Proposed Rule that will, if adopted, require certain nonbank covered entities—including consumer reporting agencies (CRAs)—to register certain...more

Bradley Arant Boult Cummings LLP

OCC Proposes Clarification to True Lender Doctrine

Earlier this week, the OCC released a proposed rule designed to address the “true lender” doctrine, a legal test utilized by courts and regulators to determine whether a bank or its non-bank partner is the actual lender in a...more

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