Exercises FDIC Lending Regulation 
CFPB Monitor
MAY 6, 2021
The OCFR claims that the Bank’s failure to hold the required lending licenses makes the loans unenforceable and prohibits Atlanticus/Fortiva from collecting any amounts on the loans. In addition, legal challenges to the OCC and FDIC “ Madden -fix” rules and the OCC’s “true lender” rule continue to create uncertainty for participants.
South State Correspondent
AUGUST 21, 2022
Lending Discipline: Hedging programs make loan pricing more transparent and force bankers to exercise sensible pricing methodologies. Second, community banks should use FDIC-insured institutions as hedge providers, and the hedges must be structured as qualified financial contracts (QFC).
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Abrigo
SEPTEMBER 5, 2023
unsecured lending is bad rather than unsecured lending should only be extended to high pass risk rated credit). As the FDIC said recently: Exceptions to policy should be few in number and properly justified, approved, and tracked. Get details in "A guide to implementing credit policy."
Abrigo
NOVEMBER 11, 2019
ALM | 4 minute read Key Takeaways Many financial institutions view asset/liability management as a "check-the-box" regulatory exercise. Obviously, protecting financial institutions against the impact to capital and earnings of rising interest rates has been the particular focus of regulators for more than a decade. Asset/Liability.
Jeff For Banks
AUGUST 2, 2014
My firm will occasionally provide feedback on correspondence to our clients'' regulators. I thought about what we should have said to the regulator, versus the sweet words I was encouraging our client to use. Below is a sample letter to your regulator, saying it like you mean it. Today we did just that. Truth is, I haven''t.
CFPB Monitor
JULY 22, 2020
24, 1464(c), and 371, respectively) that allow national banks and federal savings associations to extend credit do not indicate how to determine when a bank has exercised such authority and, rather than its relationship partner, has made a loan. Presumably, we will soon see a proposed “true lender” rule from the FDIC.
CFPB Monitor
OCTOBER 6, 2022
As alleged the Commissioner is not attempting to regulate the transfer of loans in the secondary market. Unless it settles, it creates a risk to the viability of bank model online lending that is structured like OppFi’s Program. We have helped several banks and non-banks engage in this exercise.
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