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State AGs submit comments to FDIC on small-dollar lending

CFPB Monitor

A group of 13 state attorneys general and the District of Columbia AG have sent a letter to the FDIC commenting on the agency’s request for information on small-dollar lending. They recommend that “the FDIC discourage banks from entering into these relationships in any guidance it issues on small-dollar lending.”.

FDIC 74
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Entering the cannabis banking market

Independent Banker

Our compliance program, based on elevated risk, is very robust. However, the ambiguous legal landscape complicates compliance; 47 states, the District of Columbia and four U.S. Our compliance program, based on elevated risk, is very robust,” she notes. “We Digital path to compliance. in Longview, Wash.

Marketing 113
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Democratic House members urge Kraninger to resume MLA exams

CFPB Monitor

Twenty-three Democratic members of the House Financial Services Committee have sent a letter to Kathy Kraninger, the CFPB’s new Director, urging the Bureau to resume examining its supervised entities for compliance with the Military Lending Act (MLA).

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Banking Computer-Security Incident Notification Requirements Take Effect

Abrigo

In this guest column by Jeffrey Taft and Matthew Bisanz of Mayer Brown 's Financial Services Regulatory & Enforcement practice, learn more about how to be ready for compliance. The new requirements become effective on April 1, 2022, but compliance is not required until May 1, 2022. Lending & Credit Risk. How and When.

Security 195
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State AGs criticize CFPB plans to end MLA exams

CFPB Monitor

In addition to describing the benefits that the MLA provides to servicemembers, the AGs assert that the Bureau “would be failing to abide by its statutorily mandated duty to enforce the MLA by restrictively interpreting its examination authority to preclude lenders’ compliance with the MLA.” They cite to the MLA provision (10 U.S.C.

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Eight state attorneys general file lawsuit seeking to overturn OCC’s true lender rule

CFPB Monitor

However, the AG plaintiffs in the new lawsuit instead view the Rule as “an unlawful attempt” by the OCC to “facilitate predatory lending” and support “rent-a bank schemes.”. If a bank fails to satisfy its compliance obligations, the OCC will not hesitate to use its enforcement authority consistent with its longstanding policy and practice.

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Fans and Foes of OCC True Lender Rule Spar at Senate Committee “Rent-a-Bank” Hearing

CFPB Monitor

Since the non-bank entity frequently is a fintech, these arrangements often are referred to as bank-fintech partnerships or marketplace lending arrangements. These speakers consistently conflated payday lending and bank-fintech partnership lending, and ignored correction of this mis-characterization by other witnesses.