Bank Notes

Regulatory Compliance & Agency Engagement
October 29, 2020
Agencies Propose Regulation on the Role of Supervisory Guidance
On Thursday, October 29, 2020, the five federal financial regulatory agencies issued a press release inviting comment on a proposal outlining and confirming the agencies’ use of supervisory guidance for regulated institutions. The proposal would codify the statement, as amended, that was issued in September 2018 by the agencies that clarified the differences between regulations and guidance...
Deposits & Payments
October 29, 2020
Federal Reserve Board publishes detailed noncash payments data from the 2019 Federal Reserve Payments Study
On Thursday, October 29, 2020, the Federal Reserve Board published detailed noncash payments data from the 2019 Federal Reserve Payments Study (FRPS). The additional data, estimated from surveys covering 2012 through 2018, supplement the noncash payments overview provided by the top-line data released in December 2019. The FRPS Detailed Data Release includes new information about core noncash...
CFPB, Regulatory Compliance & Agency Engagement
October 29, 2020
Consumer Financial Protection Bureau Issues Final Rule, Improves Clarity And Transparency By Amending Disclosure Of Records And Information Regulation
On Thursday, October 29, 2020, the Bureau issued a final rule amending its Disclosure of Records and Information Regulation. The rule seeks to balance concerns regarding the Bureau’s need to protect confidential personal, business, supervisory, and investigative information against the need to use and disclose certain information in the course of the Bureau’s work or the work of other agencies...
Student Lending
October 28, 2020
CBA Statement on CFPB Student Lending Ombudsman Report
On Wednesday, October 28, 2020, CBA President and CEO Richard Hunt issued the following statement after the Consumer Financial Protection Bureau issued its annual report on student lending: “The latest report from the CFPB ombudsman points out what everyone paying attention to the student lending marketplace already knows: Private lenders are working responsibility with their borrowers to set...
Mortgage and Home Equity
October 27, 2020
Consumer Financial Protection Bureau Announces Settlement With Washington Federal Bank, N.A. For Flawed Mortgage-Loan Data Reporting
On Tuesday, October 27, 2020, the Bureau settled with Washington Federal Bank, N.A., a federally insured national bank, to address the Bureau’s finding that it reported inaccurate Home Mortgage Disclosure Act (HMDA) data about its mortgage transactions for 2016 and 2017. Inaccurate HMDA data can make it difficult for the public and regulators to discover and stop discrimination in home mortgage...
Regulatory Compliance & Agency Engagement
October 27, 2020
Office of the Comptroller of the Currency Issues True Lender Rule
On Tuesday, October 27, 2020, the OCC issued a press release regarding a rule that determines when a national bank or federal savings association (bank) makes a loan and is the “true lender,” including in the context of a partnership between a bank and a third party. Banks’ lending relationships with third parties can facilitate access to affordable credit. However, increasing legal uncertainty...
Consumer Protection
October 26, 2020
Consumer Financial Protection Bureau Settles with Ninth Mortgage Company to Address Deceptive Loan Advertisements Sent to Servicemembers and Veterans
On Monday, October 26, 2020, the Bureau issued a press release regarding a consent order against Low VA Rates LLC (Low VA Rates) to address the Bureau’s finding that Low VA Rates sent consumers mailers for mortgage loans guaranteed by the U.S. Department of Veterans Affairs (VA) that contained false, misleading, and inaccurate statements. Low VA Rates’ conduct violated the Consumer Financial...
CFPB
October 20, 2020
CFPB Final Rule Extending GSE Patch
On Tuesday, October 20, 2020, the CFPB issued a final rule to extend the Government-Sponsored Enterprise (GSE) Patch until the mandatory compliance date of the final rule amending the General Qualified Mortgage (QM) loan definition in Regulation Z. The GSE Patch was originally schedule to expire January 10, 2021. The Bureau is not amending the provision in Regulation Z stating the GSE Patch will...
Regulatory Compliance & Agency Engagement
October 20, 2020
Proposed Rule on The Role of Supervisory Guidance
On Tuesday, October 20, 2020, the OCC, Federal Reserve Board, FDIC, NCUA, and CFPB (collectively, the agencies) issued a press release inviting comment on a proposed rule that would codify the Interagency Statement Clarifying the Role of Supervisory Guidance issued by the agencies on September 11, 2018; the so-called “guidance on guidance” document. The proposed rule codifies the 2018 Statement...
CBA General Programs
October 20, 2020
Agencies Finalize Rule to Reduce the Impact of Large Bank Failures
On Tuesday, October 20, 2020, the federal bank regulatory agencies issued a press release finalizing a rule to limit the interconnectedness and reduce the impact from failure of the largest banking organizations. The final rule is substantially similar to the proposal announced last year and complements other measures that the agencies have taken to limit interconnectedness among the largest...