Bank Notes

  • 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...
  • December 8, 2017
    This week, Congress took the next major step in getting a tax reform bill to the president’s desk. The House passed its version of tax reform the week before Thanksgiving, with the Senate passing its version last week. There are several differences between the two bills. As a result, a conference committee will meet to reconcile the differences. On Monday, December 4, 2017, the House voted on a...
  • December 7, 2017
    On Thursday, December 7, 2017, the FDIC, OCC and the Federal Reserve Board announced their support for the conclusion of efforts to reform the international bank capital standards initiated in response to the global financial crisis. The agencies will consider how to appropriately apply these revisions to the Basel III reform package in the United States and any proposed changes based on this...
  • December 6, 2017
    On Wednesday, December 6, 2017, the CFPB Ombudsman’s Office published its annual report highlighting the office’s selection as one of four case studies in an Administrative Conference of the US study on the use of ombudsmen in federal agencies, how the Ombudsman’s Office can assist the Bureau, internal and external engagement, and examples of how the Office resolves issues. In the report, the...
  • November 29, 2017
    On Wednesday, November 29, 2017, the OCC issued its final rule to address concerns relating to the exercise of default rights of certain financial contracts that could interfere with the orderly resolution of systemically important financial firms. The final rule requires a covered bank to ensure all covered qualified financial contracts (QFC) meet the following criteria: Contain a contractual...

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