CFPB Monitor

SEPTEMBER 23, 2019

I don’t understand why Professor Levitan is attacking the OCC and FDIC for filing an amicus brief in an “obscure small business bankruptcy case to which a bank was not even a party.” The brief was an exceptional piece of drafting and analysis and the banking agencies do not deserve to be denigrated for a supposed lack of class here.

FDIC 60

FDIC National System Analysis 60

South State Correspondent

AUGUST 21, 2022

Meet Competitive Pressures: National and larger regional banks are specifically targeting better borrowers for seven, ten, or 20-year fixed-rate loans. Second, community banks should use FDIC-insured institutions as hedge providers, and the hedges must be structured as qualified financial contracts (QFC). Conclusion.

How To 195

How To Community Bank Community FDIC 195

CFPB Monitor

JUNE 1, 2020

In that decision, the Second Circuit held that a nonbank that purchased charged-off loans from a national bank could not charge the same rate of interest on the loan that Section 85 of the National Bank Act allowed the national bank to charge. Midland Funding. 85] [12 U.S.C 85] [12 U.S.C

FDIC 78

FDIC National Lending Analysis 78

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. ” Click here to register. Our thoughts.

FDIC 78

FDIC Regulation Community Retail 78

PYMNTS

JULY 15, 2019

Analysts note that today, the percentage of professionals working in the agricultural sector remains so low that including them in national jobs calculations would not have a statistically relevant effect on overall analysis. “As percent: the growth rate of FDIC-insured bank loans to farm borrowers as of March 2019.

FDIC 142

FDIC Analysis Lending Data 142

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 our view, the court’s analysis is misguided. According to both courts, a “substance over form” analysis is inappropriate when assessing whether a transaction or a party to the transaction falls under a constitutional or statutory exemption from the usury prohibition. Opportunity Financial, LLC and Beechum v.

California 78

California FDIC Analysis Utah 78

CFPB Monitor

JANUARY 5, 2021

federal district court to block the OCC from granting a national bank charter to Figure Technologies Inc. federal district court challenging the OCC’s authority to issue special purpose national bank (SPNB) charters to non-depository fintech companies. The Conference of State Bank Supervisors (CSBS) has filed a lawsuit in D.C.

Conference 78

Conference Technology District of Columbia FDIC 78

CFPB Monitor

MAY 4, 2021

federal district court seeking to block the OCC from granting a national bank charter to Figure Technologies Inc. The lawsuit represents CSBS’s third challenge to the OCC’s authority to issue special purpose national bank (SPNB) charters to non-depository fintech companies. The first two lawsuits were dismissed on ripeness grounds.

Technology 78

Technology National Regulation FDIC 78

Abrigo

MARCH 25, 2020

The FDIC chairman had earlier asked FASB to exclude coronavirus-related modifications from being labeled a concession when determining a TDR, saying that while regulators encouraged working with borrowers, institutions worried modifications would trigger a TDR classification. Modifications not automatically TDRs.

FDIC 150

FDIC Regulation Exercises Community 150

CFPB Monitor

JANUARY 28, 2021

On June 25, 2020, the National Community Reinvestment Coalition (“NCRC”) and California Reinvestment Coalition filed a lawsuit against the OCC, asking a federal district court to declare the OCC’s CRA final rule unlawful and set it aside.

Community 131

Community FDIC Lending Survey 131

Abrigo

NOVEMBER 22, 2021

Numerous regulatory resources go into detail, including fair lending videos from the FDIC and examination procedures published on the Consumer Financial Protection Bureau’s website. However, according to the FDIC , they can be deemed as such based on their information sharing practices. Credit Analysis Training. Learn More.

Compliance 195

Compliance Lending Risk Management Regulation 195

CFPB Monitor

JULY 14, 2022

It also cites cases from other courts, including a California federal district court’s decision in CashCall , that have used a “true lender” analysis to uphold usury challenges. OppFi also argues in the Demurrer that the DFPI’s other CFL claims fail as a matter of law.

California 78

California Innovation Utah Texas 78

CFPB Monitor

JULY 9, 2020

The OCC’s decision to hurriedly issue the final rule on May 20, 2020 without achieving consensus with the FDIC, the agency with which the OCC had jointly issued the proposed rule, has drawn the ire of both consumer advocacy groups and Congress. First, consumer advocates have vigorously opposed the rule.

Groups 140

Groups Community FDIC California 140

CFPB Monitor

MAY 6, 2019

In doing so, the court found that the term “business of banking” as used in the National Bank Act (NBA) “unambiguously requires receiving deposits as an aspect of the business.”. National Resources Defense Council, Inc. The court’s textual analysis started with a review of the powers of national banks under the NBA.

Fintech 68

Fintech New York National Regulation 68

Abrigo

MARCH 17, 2022

The Federal Reserve Board, OCC, and FDIC provided two hypothetical scenarios: baseline and severely adverse. The stress test scenarios present hypothetical levels on common national level economic factors. Baseline & Severely Adverse. What's in the 2022 stress test scenarios.

Capital 195

Capital Regulation Risk Management Community 195

CFPB Monitor

NOVEMBER 24, 2020

In its background discussion explaining its rationale for the proposal, the OCC takes aim at denials of financial services by banks to categories of customers “even when an individual customer would qualify for the financial service if evaluated under an objective, quantifiable risk-based analysis.”

Operations 78

Operations Industry Analysis Policies 78

PYMNTS

JANUARY 25, 2018

In the most recent PYMNTS Global Cash Index, United States Analysis found that Americans spent $2.5 trillion in cash in 2015, a higher rate than that of Western European nations. The same FDIC report found that 70 percent of underbanked consumers had access to a smartphone, compared to 40 percent for unbanked respondents.

ATM 100

ATM Millennials FDIC New Jersey 100

Abrigo

JUNE 4, 2019

The Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), the Board of Governors of the Federal Reserve System (FRB), and the Office of the Comptroller of the Currency (OCC) have put out a joint statement addressing many frequently asked questions about the new standard.

Policies 188

Policies Capital Report FDIC 188

Insights on Business

MARCH 5, 2019

On December 3, 2018, five US government agencies, including the Federal Reserve, FDIC, FinCEN, National Credit Union Administration and OCC, issued the Joint Statement on Innovative Efforts to Combat Money Laundering and Terrorist Financing encouraging banks to implement innovative approaches and specifically referencing artificial intelligence.

Regulation 70

Regulation Compliance Analysis Innovation 70

Jeff For Banks

MAY 20, 2017

To remind readers, in 2006 the OCC, Federal Reserve, and FDIC issued joint interagency Guidance on Concentrations in Commercial Real Estate Lending. The OCC did an excellent analysis of the impact of this guidance in 2013. They need a marketing person to title their reports. Maybe sub out an economist or two. Whatever that means.

Lending 60

Lending Regulation Community Community Bank 60

CFPB Monitor

JUNE 15, 2020

The OCC acted alone in issuing the final CRA rule without waiting to achieve consensus with the FDIC, the agency with which the OCC had jointly issued the proposed rule. Our next blog post will address differences among the OCC’s final rule, the FDIC’s proposed rule, and the Federal Reserve’s existing regulations.

Community 60

Community FDIC Lending Examples 60

Abrigo

JUNE 2, 2021

Risk assessment is not thorough enough or not current: Ensure that your enterprise-wide risk assessment includes all areas of risk and dives into deep analysis where inherent risk is higher. Procedures do not match board-approved policy: Look and compare the two documents to confirm they are aligned.

How To 195

How To Training Compliance Policies 195

CFPB Monitor

JULY 12, 2022

Recognizing again that the CDD rule does not require additional due diligence for PEPs, and instead will depend on the level of CDD analysis appropriate for the customer risk. In addition to the more recent ATM Statement, FinCEN previously has made a similar statement regarding PEPs.

Regulation 78

Regulation ATM Operations Policies 78

FICO

MARCH 8, 2021

Analysis of credit repayment trends on millions of de-identified checking and savings accounts shows that a consumer who has been actively maintaining a checking or savings account balance over time and steering clear of a negative account balance is likely to be a better credit risk than someone who has not. Increasing Lender Confidence.

Data 52

Data Innovation Examples Study 52

Filene

JULY 18, 2018

The lack of access to culturally relevant, fair, dignified – and vital – financial education, products and services is made worse by a cloudy legislative commitment to fixing the nation’s broken immigration system. The FDIC says more than 45 percent of Hispanic households were unbanked or underbanked in 2015.

Community 28

Community Study Resources Lending 28

PYMNTS

JANUARY 31, 2019

is set to see its first new community bank in decades, as the Federal Deposit Insurance Corporation (FDIC) lent its approval for MOXY Bank to launch in Washington, D.C. The FDIC’s announcement said a private placement offering will raise at least $25 million for the bank ahead of its launch. . Bloomberg listed Casey G.

Community Bank 122

Community Bank Community FDIC Marketing 122

American Banker

AUGUST 8, 2016

Under pressure from regulators to beef up risk management in commercial real estate lending, banks are using new software tools to improve analysis.

Big Data 28

Big Data Risk Management Data Analysis 28

PYMNTS

SEPTEMBER 21, 2020

By way of example: ICIJ’s analysis, according to its site , found that in half of the reports, banks didn’t have information about many of the entities that were tied to the transactions. “In Much of those revamped efforts come, perhaps not surprisingly, through advanced technologies.

Fraud 347

Fraud Report System FDIC 347

FICO

JULY 17, 2017

Adding to these legislative initiatives are such must-do items as flood insurance, appropriations funding, the FAA Authorization Act, the National Defense Authorization Act and, of course, the lifting of the debt ceiling. There are even rumblings of serious work on housing finance reform. And now there is even more on Congress’s plate.

US 40

US Leadership Regulation Policies 40