Abrigo

MARCH 17, 2022

The Stress Test Scenarios for Big Banks Are Useful for Smaller Institutions' Own Tests Banking regulators recently released the 2022 scenarios for upcoming stress tests by the biggest banks. The Federal Reserve Board, OCC, and FDIC provided two hypothetical scenarios: baseline and severely adverse. Related Subhead.

Capital 195

Capital Regulation Risk Management Community 195

CFPB Monitor

OCTOBER 19, 2020

Key takeaways regarding the implications of a blue wave scenario include the following: Chris Willis commented that the CFPB’s approach to the exercise of its authorities is likely to reflect criticism by Democrats that the CFPB has been lax in its approach to industry under Director Kraninger’s leadership. (In

Leadership 78

Leadership FDIC Exercises Lending 78

CFPB Monitor

FEBRUARY 19, 2021

(Similar uncertainty exists as to the OCC’s “true lender” rule and the FDIC’s Madden -fix rule which are also the subject of pending litigation. The OCC only has authority to regulate the conduct of banks. Unlike contract rights, Section 85 preemption is a statutory privilege that cannot be assigned.

FDIC 78

FDIC National Illinois Exercises 78

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.

National 78

National Lending Exercises FDIC 78

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.

California 78

California FDIC Analysis Utah 78

CFPB Monitor

OCTOBER 29, 2020

24, 371 and 1464(c), respectively) that allow national banks and federal savings associations to engage in lending, by clarifying when a bank has exercised its lending authority. We continue to hope for a substantially similar “true lender” rule from the FDIC.

National 60

National Lending Exercises FDIC 60

CFPB Monitor

MAY 6, 2019

The OCC also argued that the NYDFS’s claims were untimely because it can no longer challenge the OCC’s long-standing regulation (12 C.F.R. The OCC argued that the NYDFS’ complaint failed to state an APA claim because this regulation is entitled to deference under the U.S. e)(1)) interpreting the term “business of banking” in the NBA.

Fintech 68

Fintech New York National Regulation 68

CFPB Monitor

SEPTEMBER 8, 2016

The Department of Defense (DoD) has issued an interpretive rule to assist the industry in complying with its July 2015 final rule amending the Military Lending Act’s implementing regulation.

Compliance 60

Compliance FDIC Security Regulation 60