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ABA issues white paper on agency guidance and sends letters to regulators commenting on recently-issued guidance

CFPB Monitor

The American Bankers Association (ABA) has issued a new white paper , “Effective Agency Guidance: Examining Bank Regulators’ Guidance Practices,” that is intended to help agencies issue guidance that complies with legal requirements while providing useful advice and information to regulated entities.

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Trade groups take aim at CFPB’s expansion of UDAAP authority

CFPB Monitor

The white paper concludes as follows: The CFPB’s action has tremendous implications for consumers, banks, and for financial markets at large. In addition to joining with the other trade groups in sending the letter and white paper to Director Chopra, the U.S.

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CFPB participates in Fed webinar on overdraft practices

CFPB Monitor

In addition to a CFPB representative, the presenters included representatives from the Fed, FDIC, OCC and NCUA. She also noted the CFPB’s June 2013 white paper and July 2014 report on checking account overdraft services. A copy of the slides used by the presenters can be found here.

FDIC 76
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CFPB to participate in Fed webinar on overdraft practices

CFPB Monitor

In addition to a CFPB representative, the speakers will include representatives from the Fed, FDIC, OCC and NCUA. It has issued a June 2013 white paper and a July 2014 report on checking account overdraft services. The presentation will be followed by a Q&A segment. Information about registration is available here.

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Ballard Spahr attorneys complete White Paper on bank-model lending

CFPB Monitor

With help from Ballard Spahr colleagues Mindy Harris and Ron Vaske, I have now completed a months-long project in updating and expanding a 2017 White Paper addressing bank-model lending—programs involving partnerships between banks (or savings associations) and fintech or other nonbank companies in the interstate delivery of loans.

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Why are banks slow to adapt alternative credit data? I'll tell you why!

Jeff For Banks

According to the FDIC , disparate impact occurs when a policy or practice applied equally to all applicants has a disproportionate adverse impact on applicants in a protected group. They have to find out later, after a bureaucrat in Washington does a white paper. But bankers won't know that when they establish the criteria.

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CFPB Director Chopra warns banks—and bank executives—about overdraft practices

CFPB Monitor

For a number of reasons and as detailed at greater length in a CBA white paper we helped author, we believe that formal rulemaking would serve as a far better approach than a return to “regulation by enforcement.”. The CFPB has had years to initiate rulemaking establishing clear standards for overdraft fees.