Regulatory Compliance & Agency Engagement

  • May 29, 2020
    CBA on OCC “Valid When Made” Final Rule WASHINGTON, D.C. – The Consumer Bankers Association today released the following statement after the Office of the Comptroller of the Currency issued a final rule clarifying the “valid when made” standard on the sale and purchase of loans: “CBA appreciates the OCC’s efforts to clarify years of uncertainty caused by the Madden case,” said CBA President and...
  • March 9, 2020
    March 9, 2020 The Honorable Mike Crapo Chairman Committee on Banking, Housing and Urban Affairs 534 Dirksen Senate Office Building Washington, D.C. 20510 The Honorable Sherrod Brown Ranking Member Committee on Banking, Housing and Urban Affairs 534 Dirksen Senate Office Building Washington, D.C. 20510 Dear Chairman Crapo and Ranking Member Brown: The Consumer Bankers Association (CBA) submits the...
  • February 14, 2020
    On Thursday, October 3, 2019, the OCC issued a final rule implementing the stress testing requirements of section 165(i)(2) of the Dodd-Frank Wall Street Reform and Consumer Protection Act, consistent with section 401 of the Economic Growth, Regulatory Relief, and Consumer Protection Act. The new rule is effective as of Nov. 24, 2019, and revises: the minimum threshold for national banks and...
  • 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 6, 2020
    “I find it hard to believe we have people who are opposed to more transparency, more consistency,” said Richard Hunt, president of the Consumer Bankers Association, who said his member banks are still studying the proposal but are pleased with its overall direction.
  • December 18, 2019
    Banks and public advocacy groups agree that the Community Reinvestment Act needs to change. But is the latest proposal moving in the right direction?
  • December 6, 2019
    Dear Mr. Becerra: The Consumer Bankers Association (“CBA” or “the Association”) appreciates the opportunity to offer our views on the California Attorney General’s (“the Attorney General” or “the AG”) Notice of Proposed Rulemaking (the “Proposed Rule” or the “Draft Regulations”) concerning California’s regulatory approach to the California Consumer Privacy Act (the “Act” or “the CCPA”). CBA...
  • 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 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...

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