Perficient

MARCH 10, 2021

.” SNC (pronounced like the candy bar but without the “ers”) stands for the Shared National Credit Program, which, since 1977, has assessed risk in the largest and most complex credits shared by multiple regulated financial institutions. Loan reviews are completed in the first and third calendar quarters each year.

National 309

National Regulation FDIC Retail 309

CFPB Monitor

DECEMBER 18, 2020

The Attorneys General of California, Illinois, and New York have filed a motion for summary judgment in their lawsuit filed against the Office of the Comptroller of the Currency (OCC) to enjoin the OCC’s final rule purporting to override the Second Circuit’s Madden decision as to national banks and federal savings associations.

FDIC 78

FDIC District of Columbia North Carolina New Jersey 78

CFPB Monitor

JULY 22, 2020

Less than two months after issuing its final “ Madden fix” rule , the OCC has now issued a proposed rule to address when a national bank or federal savings association should be considered the “true lender” in the context of a third party relationship. Presumably, we will soon see a proposed “true lender” rule from the FDIC.

National 78

National Lending Exercises FDIC 78