Bank Notes

  • 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...
  • November 15, 2019
    OCC Unified Agenda: The OCC Fall 2019 Unified Agenda comes with few surprises. CRA reform is the priority issue for CBA and, as expected, the agency will be moving forward with a proposed rule by mid-December. Also of note, Incentive-Based Compensation Arrangements is on the OCC’s list. It appears the agenda is for the agencies to issue a final rule pursuant to these requirements by year-end...
  • October 30, 2019
    On Wednesday, October 30, 2019, the CFPB, in coordination with the Minnesota Attorney General, North Carolina Department of Justice, and the Los Angeles City Attorney, announced an action to stop alleged unlawful conduct by several related student-loan debt-relief companies. The Bureau alleges that since at least 2015, the debt-relief companies operated as a common enterprise and deceived...
  • October 15, 2019
    On Tuesday, October 15, 2019, the Bureau Private Education Loan Ombudsman issued the 2019 Annual Report showing that from September 1, 2017 through August 31, 2019 the Bureau handled approximately 20,600 complaints related to private or federal student loans. Of these, there were approximately 6,700 private student loan complaints and 13,900 federal student loan complaints. The report also...
  • October 11, 2019
    On Friday, October 11, 2019, the Bureau announced that it will establish a taskforce to examine ways to harmonize and modernize federal consumer financial laws. The Taskforce on Federal Consumer Financial Law will examine the existing legal and regulatory environment facing consumers and financial services providers and report to Director Kraninger its recommendations for ways to improve and...

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