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Joint Guidance Provided to Banks to Manage Risks Associated With Third-Party Relationships

Perficient

Often an organization will have a state-charted non-member bank, which has the FDIC as its primary federal regulator. The same organization will typically have a national bank charter, and the OCC is the primary federal banking regulator for that part of the organization.

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Republican Senators seek action from FDIC to ensure end of Operation Choke Point

CFPB Monitor

Thirteen Republican Senators have sent a letter to FDIC Chairman Jelena McWilliams urging the FDIC to take action to ensure that lawful businesses are no longer at risk of adverse financial consequences as a result of “Operation Choke Point, and its associated culture and Choke Point-like regulatory actions.”.

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Community Banks Aim To Amplify Competitive Edge With FinTechs

PYMNTS

With big banks pulling back from small and medium-sized business (SMB) lending in the wake of the global financial crisis, the market was ripe for someone else to fill the credit gap. Community banks approved 49 percent of SMB loan applications in November, according to the latest data from the Biz2Credit Small Business Lending Index.

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California court rejects OppFi’s attempt to block DFPI’s “true lender” challenge to loans made through bank partnership

CFPB Monitor

Thus, there was no doubt in Jones that [a national bank] was the actual lender and that [the national bank] qualified for an exemption from the usury restrictions. Unless it settles, it creates a risk to the viability of bank model online lending that is structured like OppFi’s Program.

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Bank/nonbank partnerships could face CFPB scrutiny

CFPB Monitor

To date, CFPB enforcement actions have raised “rent-a-charter” challenges only in the context of tribal lending, most notably in its enforcement action against CashCall. Nonbank/bank partnerships are currently under siege from several directions.

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OCC CRA Final Rule – Opposition from Consumer Advocacy Groups and Congress

CFPB Monitor

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. Maxine Waters (D-CA) and Rep.

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Banking Regulators Issue Exemption from CIP Requirements for Premium Finance Loans

CFPB Monitor

1010.100(d) — and their subsidiaries which are subject to the jurisdiction of the OCC, Federal Reserve, FDIC, or NCUA. corporations, partnerships, sole proprietorships, and trusts) to facilitate the purchases of property and casualty insurance policies, otherwise known as premium finance loans or premium finance lending.