Bank Notes

  • February 3, 2020
    Today, the FDIC Office of Inspector General published an Evaluation Report of the FDIC’s Cost Benefit Analysis Process for Rulemaking. As detailed in the report findings, the OIG concluded the FDIC’s cost benefit analysis process is not consistent with widely recognized best practices. Specifically, the OIG found: The FDIC had not established and documented a process to determine when and how to...
  • January 30, 2020
    On Thursday, January 30, 2020, five federal financial regulatory agencies issued a joint press release inviting the public to comment on a proposal to modify regulations implementing the Volcker rule's general prohibition on banking entities investing in or sponsoring hedge funds or private equity funds—known as "covered funds." The joint agency proposal would improve and streamline the covered...
  • January 13, 2020
    The Consumer Bankers Association (CBA) today wrote House Financial Services Consumer Protection and Financial Institutions Subcommittee Chair Greg Meeks (D-N.Y.) and Ranking Member Blaine Luetkemeyer (R-Mo.) to discuss efforts to modernize the Community Reinvestment Act. “CBA believes banks have an affirmative obligation to help meet the credit needs of their communities, including low- and...
  • January 10, 2020
    On, Friday, January 10, 2020, the CFPB granted a no-action letter (NAL) to Bank of America regarding the bank’s funding arrangements with housing counseling agencies certified by the U.S. Department of Housing and Urban Development (HUD). The more than 1,600 HUD-certified HCAs serve more than one million households annually. They offer pre-purchase homeownership counseling to potential borrowers...
  • December 3, 2019
    On Tuesday, December 3, 2019, the Federal Reserve, CFPB, FDIC, NCUA and OCC issued a joint statement which highlights the benefits to consumers that flow from the use of alternative data in underwriting. The statement emphasizes financial institutions considering the use of alternative data in underwriting must have a robust and well-designed compliance program to ensure compliance with consumer...
  • December 3, 2019
    On Tuesday, December 3, 2019, the CFPB issued a Notice of Proposed Rulemaking (NPRM) related to the Remittance Rule (Rule). Under the current Rule, companies that provide remittance transfers in the normal course of business are required to disclose to consumers the fees and exchange rates applied to transfers. The Rule also allows banks to estimate certain fee and exchange rate information...
  • December 3, 2019
    On Tuesday, December 3, 2019, the FDIC, Federal Reserve, OCC, and FinCEN issued a joint statement today providing guidance about the Bank Secrecy Act implications of providing banking services to customers engaged in hemp production. The statement clarifies that because hemp is no longer a Schedule I controlled substance under the Controlled Substances Act, banks are not required to file a...
  • November 20, 2019
    On Wednesday, November 20, 2019, the Bureau released a Request for Information (RFI) asking for feedback on Integrated Mortgage Disclosures Under the Real Estate Procedures Act and the Truth In Lending Act, as well as certain amendments in accordance with Section 1022(d) of Dodd-Frank. Under the RFI, the Bureau asks for comment on its plan to asses the rule as well as recommendations that may be...
  • November 20, 2019
    Today, the FDIC Board of Directors unanimously approved the bank merger application submitted by BB&T to merge with SunTrust. Also today, the Federal Reserve Board issued an Order approving merger of the banks’ holding companies. The combined bank will be named Truist and will become the nation's sixth-largest retail lender, behind JPMorgan Chase, Bank of America, Citigroup, Wells Fargo and U...
  • November 19, 2019
    On Tuesday, November 19, 2019, the FDIC Board of Directors met in open session and voted to issue two notices of proposed rulemaking (NPR) and finalize three rules aimed at regulatory relief for large banks. Notices of Proposed Rulemaking (NPR) : Section 19 Statement of Polic y: The FDIC seeks public comment on all aspects of the FDIC’s Section 19 Statement of Policy, which provides guidance to...

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