News & Analysis as of

Overdraft Fees Federal Deposit Insurance Corporation Consumer Financial Protection Bureau (CFPB)

Nutter McClennen & Fish LLP

Nutter Bank Report: December 2024

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

Paul Hastings LLP

Daily Financial Regulation Update -- Friday December 13

Paul Hastings LLP on

December 12, 2024- The Consumer Financial Protection Bureau issued a final rule addressing overdrafts, applicable to banks and credit unions with more than $10 billion in assets. The rule was promptly challenged by...more

Husch Blackwell LLP

The CFPB in 2025: What to Expect Following the Election

Husch Blackwell LLP on

2024 has been an eventful year for the CFPB. As we detailed in June, the CFPB survived its second constitutional challenge at the Supreme Court in CFSA v. CFPB, and “[n]ewly emboldened, the CFPB’s already robust policy agenda...more

Nutter McClennen & Fish LLP

Nutter Bank Report: September 2024

The FDIC, OCC, and U.S. Department of Justice (DOJ) have coordinated the release of new policies that will govern each agency’s consideration of bank merger transactions. The FDIC and OCC each published final statements of...more

Hudson Cook, LLP

CFPB Bites of the Month - January 2024 - A Hazy Shade of Winter With the CFPB

Hudson Cook, LLP on

In this month's article, we share some of our top "bites" for the prior and current month covered during the January 2024 webinar....more

Ballard Spahr LLP

CFPB Supervisory Highlights Update Special Edition looks at “junk fees” charged in connection with deposits, auto servicing, and...

Ballard Spahr LLP on

The CFPB has released a new issue of Supervisory Highlights that carries the title “Junk Fees Update Special Edition.” The report discusses the CFPB’s examinations involving fees in the areas of deposits, auto servicing, and...more

Moore & Van Allen PLLC

New Legal Challenge Emerges to FDIC’s Supervisory Guidance on Re-presentment and Non-Sufficient Funds Fees

Moore & Van Allen PLLC on

When following supervisory scrutiny of fees charged to bank customers, the Consumer Financial Protection Bureau’s (CFPB) activities are often the focus. The Minnesota Bankers Association and Lake Central Bank of Minnesota,...more

Ballard Spahr LLP

Minnesota Bankers Association and Lake Central Bank sue FDIC over NSF fee guidance

Ballard Spahr LLP on

A complaint filed on July 20, 2023 in Minnesota federal court seeks declaratory and injunctive relief under the Administrative Procedures Act (APA) against defendants Federal Deposit Insurance Corporation (FDIC) and Chairman...more

Goodwin

FDIC Refines Supervisory Strategy Concerning Multiple Re-Presentment NSF Fees Guidance

Goodwin on

Regulatory Developments - FDIC Refines Supervisory Strategy Concerning Multiple Re-Presentment NSF Fees Guidance - On June 16, the FDIC revised its Supervisory Guidance on Multiple Re-Presentment Non-Sufficient Funds...more

Hudson Cook, LLP

CFPB Bites of the Month - June 2023 - A New Definition of Summer Madness

Hudson Cook, LLP on

In this month's article, we share some of our top "bites" for the prior month covered during the June 2023 webinar. Bite 12: CFPB Focusing on Overdraft Issues - On May 18, 2023, the CFPB announced that it had issued a...more

Orrick, Herrington & Sutcliffe LLP

CFPB releases regulatory agenda (UPDATE)

The Office of Information and Regulatory Affairs recently released the CFPB’s spring 2023 regulatory agenda. Key rulemaking initiatives that the agency expects to initiate or continue include...more

Mintz

Heightened Risk for Banks as Account Fees Land on “Junk Fee” Agenda

Mintz on

Banks and financial institutions beware: an increased focus on so-called “junk fees” has litigants and regulators alike taking aim at checking and deposit account fees. Although recent political focus on “junk fees” has been...more

Ballard Spahr LLP

OCC and FDIC address overdraft and NSF fee practices

Ballard Spahr LLP on

The OCC has issued a new bulletin and the FDIC has issued new supervisory guidance directed to their supervised institutions to address “authorize positive, settle negative” (APSN) overdraft fee practices. The OCC bulletin...more

Goodwin

Overdraft Protection Programs: Risk Management Practices

Goodwin on

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

Buchalter

CFPB Proposed Regulatory Activity Agenda Released, Focuses on Limitations on Bank and Credit Card Fees, Small Business Lending...

Buchalter on

The Office of Information and Regulatory Affairs in the Office of Management and Budget has released the Fall 2022 Unified Agenda of Regulatory and Deregulatory Actions (Agenda) reports on the actions administrative agencies...more

Spilman Thomas & Battle, PLLC

Promissory Notes - Banking & Finance Insights: Issue 12, December 2022

US Senators Ask SoFi About Its Banking Law Compliance = “Four U.S. senators have signed a letter to SoFi Technologies CEO Anthony Noto expressing concerns about the online personal finance company and online bank’s digital...more

Ballard Spahr LLP

FDIC issues guidance on multiple re-presentment NSF fees

Ballard Spahr LLP on

The FDIC has issued new supervisory guidance (FIL-40-2022) on multiple non-sufficient funds (NSF) fees arising from the re-presentment of the same unpaid transaction. The guidance directly applies only to state-chartered...more

Paul Hastings LLP

Daily Financial Regulation Update -- Thursday, July 21, 2022

Paul Hastings LLP on

July 20, 2022- The U.S. House Committee on Financial Services held a hearing entitled, "Housing in America: Oversight of the Federal Housing Finance Agency."...more

Nutter McClennen & Fish LLP

Nutter Bank Report: December 2021

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

DailyPay, Inc.

Earned Wage Access & the American Overdraft Fee Crisis

DailyPay, Inc. on

You know we have a serious economic justice problem in this country when the poorest Americans are paying $8 billion in overdraft fees in $35 increments to the nation’s largest banks. But that’s exactly what happened in 2020...more

Nutter McClennen & Fish LLP

Nutter Bank Report: September 2021

Division of Banks Warns of Risks from Representments Causing Multiple NSF Fees - The Massachusetts Division of Banks has issued a supervisory alert letter to warn banks about certain legal risks and risks of regulatory...more

Perkins Coie

Fintech Week in Review - June 2021 #2

Perkins Coie on

A buy-now pay-later company faces a potential class action alleging it hid the risk of overdraft and NSF fees from its users. Leaders of the CFPB’s Fair Lending Office published an article encouraging the use of special...more

Nutter McClennen & Fish LLP

Nutter Bank Report November 2018

Federal Banking Agencies Propose Alternative Capital Framework for Community Banks - The federal banking agencies have proposed a new community bank leverage ratio (“CBLR”) framework that would simplify regulatory capital...more

BCLP

Regulators Tackle Board Effectiveness and Overdrafts

BCLP on

Host Jonathan Hightower is joined by Ken Achenbach to discuss this week's proposed guidance from the Federal Reserve on the effectiveness of bank boards. In addition, at the outset of the episode Jonathan and Ken reviewed...more

Ballard Spahr LLP

CFPB’s Final Prepaid Card Rule: Long Form Disclosures

Ballard Spahr LLP on

The final Prepaid Card Rule requires not only so-called “packaging” or short form disclosures prior to acquisition of the prepaid card account, but also that a long form disclosure be provided to the consumer. Whereas the...more

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