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.
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.
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Jeff For Banks
FEBRUARY 6, 2011
The FDIC has nearly quadrupled its enforcement actions (“EA”) over the past three years. The productive view about the similarity of EAs is why haven’t we been doing some of the things required by regulators in the first place? Banking is a highly regulated industry, and has been since the Great Depression.
CFPB Monitor
MARCH 15, 2022
The OCC’s attempt to provide a clear bright line test for determining when a bank is the “true lender” in a bank-model program through a regulation was overturned by Congress under the Congressional Review Act.) Maryland, New York, North Carolina, Ohio, Pennsylvania, West Virginia, and Colorado.
Jeff For Banks
JUNE 2, 2023
Second, this can be accomplished only if the industry does not have too much influence over its regulators and if the regulators have the ability to hire, train, and retain qualified staff. Third, the regulators need adequate financial resources. My lesson learned to the regulators, read your past lessons learned.
Independent Banker
DECEMBER 13, 2015
These agencies had input: the Federal Reserve, the Office of the Comptroller of the Currency, FDIC and the National Credit Union Administration. No one knows yet how in-depth the regulators might want those assessments.”. Ellen Ryan is a freelance writer in Maryland.
Independent Banker
NOVEMBER 24, 2015
These agencies had input: the Federal Reserve, the Office of the Comptroller of the Currency, FDIC and the National Credit Union Administration. No one knows yet how in-depth the regulators might want those assessments.”. Ellen Ryan is a freelance writer in Maryland.
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