CFPB Monitor

MAY 6, 2021

A Maryland administrative action recently removed to the state’s federal district court illustrates how Maryland law continues to present challenges for the bank partner structure used by many lenders. The new Maryland matter demonstrates that participants in bank model programs continue to face state licensing threats.

Maryland 78

Maryland Lending Missouri FDIC 78

CFPB Monitor

SEPTEMBER 10, 2020

Because CCBank is a state-chartered FDIC-insured bank located in Utah, Section 27(a) of the Federal Deposit Insurance Act authorizes CCBank to charge interest on its loans, including loans to California residents, at a rate allowed by Utah law regardless of any California law imposing a lower interest rate limit.

Utah 78

Utah California FDIC West Virginia 78

Jeff For Banks

JUNE 2, 2023

The old borrow short, lend long strategy. I want to read to you the FDIC’s conclusion from their An Examination of the Banking Crisis of the 1980’s and Early 1990’s. Third, the regulators need adequate financial resources. My lesson learned to the regulators, read your past lessons learned. credit default swaps anyone?).

FDIC 78

FDIC Community Bank Regulation Lending 78

CFPB Monitor

JUNE 15, 2022

Four Democratic members of the California state legislature recently sent a letter to the Federal Deposit Insurance Corporation (FDIC) urging the agency to take action against FDIC-supervised banks that partner with non-bank lenders to originate high-cost installment loans.

FDIC 78

FDIC California West Virginia North Carolina 78