Bank Notes

  • February 7, 2018
    On Wednesday, February 7, 2017, the CFPB issued its third in a line of Requests for Information (RFI) on the Bureau’s enforcement processes. The Bureau is collecting information to assess the effectiveness of its processes related to enforcement of federal consumer financial laws. This is the third RFI in three weeks from the CFPB as part of Acting Director Mick Mulvaney’s call for evidence to...
  • February 5, 2018
    On Monday, February 5, 2018, five federal agencies (Board of Governors of the Federal Reserve, Farm Credit Administration, Federal Housing Finance Agency, FDIC and OCC) proposed to amend swap margin requirements to conform with recent rule changes that impose new restrictions on certain qualified financial contracts (QFCs) of systemically important banking organizations. Under the proposed...
  • February 2, 2018
    On Thursday, February 2, 2018, the OCC released economic and financial market scenarios for use in the upcoming stress tests for covered institutions with more than $10 billion in assets. The supervisory scenarios include baseline, adverse, and severely adverse scenarios, as described in the OCC’s final rule that implements stress test requirements of the Dodd-Frank Wall Street Reform and...
  • January 17, 2018
    On Wednesday, January 17, 2018, the CFPB announced it is issuing a “call for evidence” to ensure the Bureau is properly fulfilling duties to best protect consumers. The Bureau announced that in the coming weeks they will publish a series of Requests for Information (RFIs) to seek comment on enforcement, supervision, rulemaking, market monitoring, and education activities. The Bureau’s first RFI...
  • January 16, 2018
    In a statement on Tuesday, January 16, 2018, the CFPB said it intends to engage in a rulemaking process to reconsider the Small-Dollar Rule. Compliance with the rule by lenders is not mandatory until August 19, 2019, so the rulemaking would take place between now and then. As a technical matter, today was the official "effective date" of the final rule as published in the Federal Register; and...
  • January 10, 2018
    On Wednesday, January 10, 2018, the FDIC issued the Supervisory Insights , which includes articles on credit Management Information Systems (MIS) and recent results from the FDIC's Credit and Consumer Products/Services Survey. "A key component of a bank's risk management program is a strong credit MIS, which uses loan data to develop timely and meaningful reporting for a bank's board and senior...
  • January 10, 2018
    Late Wednesday, January 10, 2018, a federal court denied CFPB Deputy Director Leandra English's request for a preliminary injunction to block President Trump's appointment of Office of Management and Budget Director Mick Mulvaney as Acting CFPB Director. English, who was appointed Deputy Director just prior to former CFPB Director Richard Cordray's departure, has maintained the Dodd-Frank Act...
  • December 28, 2017
    On Tuesday, November 28, 2017, the OCC released its schedule of CRA evaluations for the first and second quarters of 2018. The OCC encourages public comment on the national banks and federal savings associations scheduled to be evaluated under the CRA, and suggests that comments be submitted prior to the month in which the evaluation is scheduled. The OCC will consider all public comments...
  • December 27, 2017
    On Wednesday, December 27, 2017, the CFPB released a biennial report on the state of the credit card market. The report states the total amount of credit line, number of accounts, average amount of card debt, and enrollment in online services have all increased steadily since the dip they took after the financial crisis of 2008. The report also found that cardholders average fewer credit cards...
  • December 21, 2017
    On Thursday, December 21, 2017, the CFPB issued a public statement announcing the Bureau does not intend to require data resubmission unless data errors are material, or assess penalties with respect to errors for data collected in 2018 and reported in 2019 under HMDA. The Bureau also announced it intends to pen rulemaking process to reconsider various aspects of the 2015 HMDA rule. The Bureau...

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