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OCC CRA Final Rule: What’s Next for the FDIC and Federal Reserve Board?

CFPB Monitor

When the OCC issued its final Community Reinvestment Act (“CRA”) rule on May 20, 2020, the agency acted alone without waiting to achieve consensus with the FDIC, the agency with which the OCC had jointly issued its proposed rule. As to the Federal Reserve Board (“FRB”), it had already bowed out of the CRA reform effort in 2019.

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OCC Highlights, AML & CRA Risks

Perficient

Additionally, the recent rule by the OCC, the Federal Reserve, and the FDIC strengthens and modernizes Community Reinvestment Act (CRA) regulations. The effective date of the new rule is April 1, 2024, with key provisions taking effect on January 1, 2026, and January 1, 2027. 

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OCC and FDIC issue proposed rules to undo Madden

CFPB Monitor

The OCC and FDIC issued proposed rules this week intended to eliminate the uncertainty created by the Second Circuit’s decision in Madden v. Comments on the OCC’s proposal must be submitted by January 21, 2020. With regard to interest rate authority, the OCC points to Section 85 (applicable to national banks) and 12 U.S.C.

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Democratic Senators introduce bill to close industrial loan company “loophole”; coalition of financial services and consumer organizations voice support for bill

CFPB Monitor

the SEC for registered brokers or dealers) or, if Section 2 does not assign a “primary financial regulatory agency,” the FDIC. The ILCs subject to this FDIC authority would include ILCs approved for deposit insurance on or before September 23, 2021. The bill is co-sponsored by Senators Bob Casey (D-Pa.) and Chris Van Hollen (D-Md.).

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OCC, FDIC, and Federal Reserve propose amendments to CRA regulations

CFPB Monitor

After moving alone in 2020 to reform its Community Reinvestment Act (CRA) regulation, the Office of the Comptroller of the Currency (OCC) has joined the Federal Deposit Insurance Corporation (FDIC) and Federal Reserve Board in issuing a joint notice of proposed rulemaking setting forth proposed amendments to their regulations implementing the CRA.

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Varo Is First FinTech to Receive Full-Service Charter from the OCC

CFPB Monitor

On July 31, 2020, the Office of the Comptroller of the Currency (OCC) approved the national bank charter application of Varo Bank, N.A., team — the first consumer fintech to receive a national bank charter. As other fintechs mature and grow nationally, the message from the federal banking system is: come on in.

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The Future of Noninterest Income at Financial Institutions

Abrigo

The Consumer Financial Protection Bureau (CFPB) in 2020 ordered TD Bank, N.A. To remain competitive, some of the nations’ largest banks have introduced new products. Ally Bank has not only eliminated overdraft fees, but refunded overdraft fees between March and June 2020 as a goodwill gesture to customers challenged by the pandemic.