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Unfair or Deceptive Trade Practices Office of the Comptroller of the Currency

Clark Hill PLC

Key Updates to the OCC's UDAAP Handbook

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The Office of the Comptroller of the Currency (OCC) has released a revised version of its Unfair or Deceptive Acts or Practices and Unfair, Deceptive, or Abusive Acts or Practices (UDAP/UDAAP) handbook. The updated handbook,...more

Troutman Pepper Locke

OCC Releases Updated UDAAP Supervision and Examination Procedures Booklet

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On December 3, the Office of the Comptroller of the Currency (OCC) issued version 1.1 of the “Unfair or Deceptive Acts or Practices and Unfair, Deceptive, or Abusive Acts or Practices” booklet of the Comptroller’s Handbook,...more

Troutman Pepper Locke

Federal and State Financial Agencies Issue Guidance on Elder Financial Exploitation

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Earlier this week, the Board of Governors of the Federal Reserve System (FRB), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Financial Crimes Enforcement Network (FinCEN), National...more

Foley & Lardner LLP

Office of the Comptroller of the Currency Updates “Unfair or Deceptive Acts or Practices and Unfair, Deceptive, or Abusive Acts or...

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Financial institutions that are regulated and supervised by the Office of the Comptroller of the Currency (OCC) should know that the OCC has recently updated its booklet on Unfair or Deceptive Acts or Practices (UDAP) and...more

Hudson Cook, LLP

CFPB Bites of the Month - October 2024 - (Don't Fear) The Reaper CFPB

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

Morrison & Foerster LLP

MoFo’s State + Local Government Enforcement Newsletter - April 2024

Morrison Foerster’s State and Local Government Task Force is pleased to provide our bimonthly newsletter summarizing some of the most important and interesting developments from state attorneys general across the country and...more

Sheppard Mullin Richter & Hampton LLP

New York Governor Consumer Protection Agenda Targets Unfair and Deceptive Practices and BNPL Providers

On January 2, 2024, New York Governor Kathy Hochul announced “a sweeping consumer protection and affordability agenda,” what she termed as the “most significant expansion of consumer laws since 1980.” As part of that agenda,...more

Ballard Spahr LLP

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

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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

The Volkov Law Group

Bank of America Hit with $250 Million in Penalties for Account Abuse Practices

The Volkov Law Group on

Bank of America joined the club of consumer abusers – Wells Fargo had been the well-established leader of this club and the poster-child for abusive consumer practices.  For years, Bank of America avoided federal...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

Cadwalader, Wickersham & Taft LLP

OCC and FDIC Provide Supervisory Guidance on Certain Overdraft Practices

The Office of the Comptroller of the Currency (“OCC”) and the Federal Deposit Insurance Corporation (“FDIC”) (collectively, the “Agencies”) provided supervisory guidance this week on certain overdraft practices. Of particular...more

Troutman Pepper Locke

OCC and FDIC Issue Separate Guidance on Overdraft Fees

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On April 26, both the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) issued separate advisories warning against the risks associated with overdraft fees, particularly...more

Morrison & Foerster LLP

Heightened Scrutiny: Federal Banking Agencies Issue Joint Statement Highlighting Key Crypto Risks

On January 3, 2023, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the “Agencies”) issued a joint...more

Goodwin

CFPB Launches New Initiative Focused on Rural Communities

Goodwin on

In This Issue. The Consumer Financial Protection Bureau (CFPB) announced a new initiative focused on financial issues faced by rural communities and also updated its examination procedures to cover unfair discrimination; the...more

Goodwin

President Biden Issues Sweeping Executive Order on Promoting Competition in the American Economy

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In This Issue. President Joe Biden issued a sweeping executive order aimed at cracking down on anticompetitive practices and reducing consolidation across multiple industry sectors, including financial services; the Federal...more

Goodwin

OCC Delays Publication Of Trump Administration “Fair Access” Rule

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In this Issue. The Office of the Comptroller of the Currency (OCC) delayed publication of the “fair access” rule finalized late in the Trump Administration; the OCC also announced the availability of the 2021 list of bank...more

Hudson Cook, LLP

CFPB Bites of the Month - December Top 20

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Each month, we host a 30-minute webinar outlining the month's key announcements and takeaways from the CFPB to be considered by financial services providers. It was a particularly busy month at the CFPB, so as an extra...more

Goodwin

SEC Adopts Rule Providing New Regulatory Framework For Fund-Of-Funds

Goodwin on

In the News. The Securities and Exchange Commission (SEC) announced that it adopted Rule 12d1-4 under the Investment Company Act of 1940 (the 1940 Act), providing a new regulatory framework for fund-of-funds and final...more

Skadden, Arps, Slate, Meagher & Flom LLP

New UDAAP Guidance Is Relevant to OCC-Regulated and Nonregulated Institutions Alike

In late June 2020, the Office of the Comptroller of the Currency issued a new booklet on “Unfair or Deceptive Acts or Practices and Unfair, Deceptive, or Abusive Acts or Practices” (the UDAAP booklet), setting forth a...more

Hudson Cook, LLP

Current Developments in Bank Deposits and Payment Systems (Spring 2020)

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This survey summarizes several recent developments affecting bank deposits and payment systems. These include payments-related consent orders and enforcement actions by the Consumer Financial Protection Bureau (“CFPB”) and...more

Goodwin

OCC and CFPB Reach $30 Million Settlement With South Dakota Bank Over Overdraft Fees

Goodwin on

On July 20, 2018, the Office of the Comptroller of the Currency (OCC) and Consumer Financial Protection Bureau (CFPB) reached a $30 million settlement with a South Dakota bank over allegations that the bank had engaged in...more

Troutman Pepper Locke

Wells Fargo Consent Orders Highlight Importance of Acting on Information From Third-Party Vendors

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The OCC and CFPB consent orders issued against Wells Fargo on April 20 cited deficiencies in third-party oversight practices. The orders are the latest additions to an ever-expanding body of agency enforcement actions...more

Ballard Spahr LLP

OCC Issues Draft Licensing Supplement for Fintech Companies Seeking National Bank Charters

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The Office of the Comptroller of the Currency (OCC) has taken another step toward implementing its proposal to allow financial technology (fintech) companies to apply for a special purpose national bank (SPNB) charter,...more

Stinson LLP

Emerging Trends Newsletter - Q4

Stinson LLP on

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

Polsinelli

Banking Agencies Issue Deposit-Reconciliation Best Practices

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Five federal regulators on Wednesday – the FDIC, the Fed, CFPB, NCUA, and OCC – issued an interagency guidance applicable to all FDIC-supervised financial institutions describing expectations for effective...more

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