CFPB Monitor

JUNE 29, 2020

The FDIC has issued its widely anticipated final rule resolving the uncertainty caused by the Second Circuit’s Madden v. The FDIC’s Notice of Proposed Rulemaking (“NPR”) was published the same week as an OCC proposed rule intended to address the same issue for national banks under Section 85. On July 20, 2020, from 12:00 p.m.

FDIC 60

FDIC National Analysis Regulation 60

CFPB Monitor

AUGUST 20, 2020

Since early June 2020 when cries for racial justice resulted in a period of social unrest in the U.S., While it remains to be seen whether these initiatives will be effective and produce lasting results, they represent a significant, concerted effort by financial services regulators to promote greater financial inclusion and equality.

Regulation 78

Regulation FDIC Community Lending 78

CFPB Monitor

DECEMBER 8, 2022

As a result, a company that controls an institution that is not a BHCA bank is not required to register as a bank holding company with the Federal Reserve Board and, therefore, is not subject to regulation and supervision by the Federal Reserve Board. 5301) (e.g.

FDIC 78

FDIC Company Industry Regulation 78

CFPB Monitor

MAY 22, 2020

The OCC has issued a final rule revising its regulation implementing the Community Reinvestment Act (CRA). The final rule applies to national banks and federal savings associations. Although the OCC’s proposed revisions were issued jointly with the FDIC, the FDIC did not join in the final rule.

FDIC 78

FDIC Lending Retail Compliance 78

CFPB Monitor

MARCH 30, 2020

The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) includes the following key provisions that affect financial institutions and regulation of financial institutions: Section 4003 – Emergency Relief and Taxpayer Provisions. Section 4008 – Debt Guaranty Authority.

Regulation 122

Regulation United States Community Bank National 122

CFPB Monitor

DECEMBER 19, 2019

The OCC and FDIC have issued a joint proposal to revise their regulations implementing the Community Reinvestment Act (CRA). Although the Federal Reserve, OCC and FDIC, are the primary CRA regulators, the Fed did not join the proposal and presumably will issue a separate proposal. On January 29, 2020, from 12 p.m.

FDIC 78

FDIC Regulation Community Retail 78

CFPB Monitor

AUGUST 7, 2020

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.

Fintech 78

Fintech FDIC Utah National 78

CFPB Monitor

MAY 7, 2020

The Bureau states that “neither ECOA nor Regulation B mandate the use of any particular list of reasons. In 2019, in addition to the Bureau’s three referrals to the DOJ, the FDIC referred two matters and the Federal Reserve and the NCUA each referred one matter. On May 20, 2020, from 12 p.m.

Lending 78

Lending Report FDIC Policies 78

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

Abrigo

MARCH 25, 2020

Key Takeaways Banking regulators say short-term, COVID-19-related loan modifications shouldn't automatically be categorized as TDRs. Regulators also announced other guidance tied to reporting and risk-based capital rules. Regulators also announced other guidance tied to reporting and risk-based capital rules.

FDIC 150

FDIC Regulation Exercises Community 150

CFPB Monitor

FEBRUARY 19, 2021

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

FDIC 78

FDIC National Illinois Exercises 78

Abrigo

NOVEMBER 22, 2021

Major consumer loan compliance regulations. Major consumer loan compliance regulations cover everything from taking applications and approving or rejecting the credit to collecting payments and reporting to the government on various aspects of the loans. Regulation Z, which implements the Truth in Lending Act (TILA).

Compliance 195

Compliance Lending Risk Management Regulation 195

CFPB Monitor

JANUARY 28, 2021

The fate of the OCC’s Community Reinvestment Act (“CRA”) final rule , issued on May 20, 2020, hangs in the balance following the inauguration of President Biden on January 20 and the resignation of former Acting Comptroller Brian Brooks, who was a major proponent of the rule, on January 14.

Community 131

Community FDIC Lending Survey 131

CFPB Monitor

SEPTEMBER 10, 2020

In 2019, California enacted AB-539, the Fair Access to Credit Act (FACA), which, effective January 1, 2020, limits the interest rate that can be charged on loans of $2,500 to $10,000 by lenders licensed under the California Financing Law (CFL) to 36% plus the federal funds rate. A number of states have challenged these regulations.

Utah 78

Utah California FDIC West Virginia 78

CFPB Monitor

MAY 22, 2020

The Federal Reserve, OCC, FDIC, and NCUA have issued “ Interagency Lending Principles for Offering Responsible Small-Dollar Loans.” Marketing and customer disclosures that comply with applicable laws and regulations and provide information in a clear, conspicuous, accurate, and customer-friendly manner.”.

FDIC 78

FDIC Policies Lending Guidelines 78

CFPB Monitor

APRIL 13, 2022

A report recently issued by the Government Accountability Office titled “ Banking Services: Regulators Have Taken Actions to Increase Access, but Measurement of Actions’ Effectiveness Could Be Improved ,” strongly suggests that banks and credit unions are unlikely to increase their small-dollar lending as consumer advocates contend.

Report 78

Report Lending FDIC Regulation 78

CFPB Monitor

JANUARY 19, 2022

federal district court in December 2020 seeking to block the OCC from granting a national bank charter to Figure Technologies Inc. The OCC indicated that in connection with this amendment, the bank organizers will apply to the FDIC for deposit insurance, and Figure Technologies, Inc. Section 5.20(e)(1)

Technology 78

Technology National FDIC Fintech 78

CFPB Monitor

JUNE 15, 2021

Three significant items that were listed as “long-term actions” in the Bureau’s Fall 2020 rulemaking agenda, the last agenda issued under former Director Kraninger, no longer appear in the Spring 2021 agenda. The comment period closed on August 4, 2020. In December 2020, the Bureau released the final report of the SBREFA panel.

Regulation 78

Regulation FDIC Lending Data 78

CFPB Monitor

NOVEMBER 29, 2021

Federal banking regulators have been busy in this space. Accordingly, “it is important that [the Agencies] provide coordinated and timely clarity where appropriate to promote safety and soundness, consumer protection, and compliance with applicable laws and regulations, including [AML] and illicit finance statute and rules.”

Compliance 78

Compliance cryptocurrency Regulation FDIC 78

CFPB Monitor

OCTOBER 19, 2020

For our webinar last week, “What a Blue Wave in the November 2020 Elections Could Mean for the Consumer Financial Services Industry,” we were joined by special guest Isaac Boltansky, Director of Policy Research at Compass Point Research & Trading.

Leadership 78

Leadership FDIC Exercises Lending 78

FICO

DECEMBER 13, 2019

The most prominent villain for fintech companies is regulation. And so it’s easy to see why a fintech company — believing fully in the virtue of its mission and faced with a litany of illogical and intractable regulations — might just say "F*ck it, we're doing it anyways." A Prediction for the 2020s. A Prediction for the 2020s.

Regulation 52

Regulation Fintech Lending Branding 52

CFPB Monitor

MARCH 15, 2022

In 2019, California enacted AB 539 which, effective January 1, 2020, limited the interest rate that can be charged on loans of $2,500 to $10,000 by lenders licensed under the California Financing Law (CFL) to 36% plus the federal funds rate. Section 7.4001(e).

California 78

California Innovation Utah West Virginia 78

CFPB Monitor

JUNE 12, 2020

Section 27, which applies to state banks, is patterned after Section 85 of the National Bank Act, which applies to national banks. In Madden , the Second Circuit ruled that a purchaser of charged-off debts from a national bank was not entitled to the benefits of the preemption of state usury laws under Section 85. to 1:00 p.m.

Colorado 78

Colorado FDIC Analysis National 78

CFPB Monitor

OCTOBER 6, 2022

In 2019, California enacted AB 539 which, effective January 1, 2020, limited the interest rate that can be charged on loans less than $10,000 but more than $2,500 by lenders licensed under the California Financing Law (CFL) to 36% plus the federal funds rate. The identity of the real lender was not at issue.

California 78

California FDIC Analysis Utah 78

CFPB Monitor

DECEMBER 16, 2020

The CFPB should rescind the July 2020 rule that rescinded the underwriting provisions in its 2017 rule on Payday, Vehicle Title, and Certain High-Cost Installment Loans (2017 Payday Rule) and reinstate the 2017 Payday Rule. The OCC and FDIC should rescind their Madden -fix rules and the OCC should rescind its “true lender” rule.

Policies 78

Policies Regulation Lending FDIC 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

PYMNTS

FEBRUARY 14, 2019

That’s because it marked the first hearing dedicated to a proposed bill in Congress that would offer financial institutions protections against federal regulators when dealing with legal cannabis operations. billion by 2020, according to State Treasurer Fiona Ma, who spoke at the hearing. In 2018, consumers in Colorado bought some $1.55

Oregon 230

Oregon Colorado Operations Washington 230

CFPB Monitor

APRIL 22, 2021

The agencies are the Comptroller of the Currency, Farm Credit Administration, FDIC, Federal Reserve Board, and National Credit Union Administration (Agencies). The proposed Q&As will supplement the proposed Q&As issued by the Agencies in July 2020. However, please see the following bullet point.

Policies 60

Policies Compliance Meeting Regulation 60

Abrigo

JUNE 2, 2021

The guidance emphasizes a risk-focused approach to examinations and refocuses the regulators to scope each exam according to the unique financial institution, not to use a one-size-fits-all approach. Although this advisory is dated 2014, it is top-of-conversation among regulators even today. BSA Rules and Regulation. Learn More.

How To 195

How To Training Compliance Policies 195

CFPB Monitor

NOVEMBER 22, 2022

In particular, the report’s recommendations deserve attention because they are likely to influence future actions by the federal banking regulators and the CFPB. (The The report is also worthwhile reading for its discussion of the role of fintechs and other non-banks in providing consumer financial services and how that role has evolved.).

Fintech 78

Fintech Report Data Lending 78

CFPB Monitor

JUNE 15, 2020

On May 20, 2020, the OCC issued a final rule to “strengthen and modernize” its existing Community Reinvestment Act (“CRA”) regulations. On June 22, 2020, from 12:00 p.m. The final rule is effective on October 1, 2020. to 1:00 p.m. ” In the webinar, we will be joined by special guest Kenneth H. 1204, Jan.

Community 60

Community FDIC Lending Examples 60

PYMNTS

FEBRUARY 13, 2019

That’s because it marked the first hearing dedicated to a proposed bill in Congress that would offer financial institutions protections against federal regulators if dealing with legal cannabis operations. billion by 2020, according to State Treasurer Fiona Ma, who spoke the hearing. In 2018, consumers in Colorado bought some $1.55

Oregon 115

Oregon Colorado Operations Washington 115

CFPB Monitor

OCTOBER 13, 2020

We recently published a blog about the OCC’s proposed rule “National Banks and Federal Savings Associations as Lenders” (the “Proposed Rule”), which would clarify that a bank (or savings association) is properly regarded as the “true lender” when, as of the date of origination, it is named as the lender in a loan agreement or funds the loan.

Lending 60

Lending Colorado FDIC National 60

FICO

DECEMBER 19, 2018

This month, the FCC approved the creation of a National Reassigned Number Database to address the nearly 100,000 wireless numbers that are reassigned each day. I believe this will slip a few months but by June 2019 the proposed regulations will finally be available for public review and comment.

Policies 40

Policies District of Columbia Regulation California 40

CFPB Monitor

JUNE 25, 2020

On May 20, 2020, the OCC issued a final rule to “strengthen and modernize” its existing Community Reinvestment Act (“CRA”) regulations. The final rule is effective October 1, 2020 but sets mandatory compliance dates based on the applicable performance standards.

Community 97

Community Lending Meeting Retail 97

CB Insights

DECEMBER 4, 2019

The 2017 FDIC National Survey of Unbanked and Underbanked Households shows: Approximately 6.5% The overall value of the insurance market in India is expected to touch $280B by 2020. According to CNBC, the company plans to roll out Go to dozens of airports and movie theaters in 2020. US households, composed of 14.1M

Cards 101

Cards Lending Strategy US 101