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Regulatory Compliance & Agency Engagement
- July 6, 2018On Friday, July 6, 2018, the Federal banking agencies issued a statement detailing rules and associated reporting requirements that are immediately affected by the enactment of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA). These changes affect company-run stress testing, resolution plans, the Volcker rule, high volatility commercial real estate exposures,...June 29, 2018On Friday, June 29, 2018, the FDIC and the Federal Reserve Board announced they are seeking public comment on revised resolution plan guidance for the eight largest, most complex U.S. banks. Resolution plans, commonly known as living wills, must describe the company's strategy for rapid and orderly resolution under bankruptcy in the event of material financial distress or failure of the company...June 29, 2018On June 29, 2018, the Bureau of Consumer Financial Protection (BCFP) announced it had settled with Citibank for alleged Truth in Lending Act violations which the company self-reported to the agency. According to the consent order , the Bureau claims the company failed to reevaluate and lower the annual percentage rates (APRs) for approximately 1.75 million consumer credit card accounts and did...June 22, 2018D.C. DOWNLOAD Court Rules Bureau’s Structure Unconstitutional – The U.S. District Court of the Southern District of New York ruled yesterday the Bureau "unconstitutionally structured." The opinion was in the case of CFPB v. RD Legal Funding, LLC et al. Whether the decision, which disqualified the Bureau as a plaintiff in the case, will be appealed depends on a number of factors. However, it is...June 15, 2018CBA's JUNE BOARD OF DIRECTORS MEETING CBA Board Meets With Regulators – Nearly the entire CBA Board of Directors met this week at our World Headquarters in Washington, D.C., and our agenda the past couple days has been nothing short of a whirlwind. We kicked off the visit weaving in-and-out of Washington Capitals fans on the D.C. Metro as we headed to meetings with OCC Comptroller Joseph Otting,...June 14, 2018On Thursday, June 14, 2018, Comptroller of the Currency Joseph Otting issued a press release discussing his priorities for the agency and the federal banking system during testimony before the Senate Committee on Banking, Housing, and Urban Affairs. The Comptroller’s testimony highlighted agency efforts to: Modernize the regulatory approach to the Community Reinvestment Act to promote investment...June 14, 2018On June 14, 2018, the Fed issued a final rule limiting the credit exposure of large financial institutions to one another. The new rule applies to globally systemically important bank holding companies (GSIBs) – or those with more than $250 billion in total consolidated assets – and caps their credit exposure to one another at 15 percent of tier 1 capital. The rule also covers foreign banks...June 13, 2018Comptroller Joseph Otting today on Wednesday, June 13, 2018, before the House Financial Services Committee to discuss his agenda at the Office of the Comptroller of Currency and other financial industry regulatory matters. Otting outlined the priorities for his time at the OCC, including: Modernizing the Community Reinvestment Act; Expanding short-term, small-dollar lending; Adjusted bank capital...June 8, 2018TESTIFYING ON CAPITOL HILL MY TESTIMONY BEFORE THE HOUSE FINANCIAL SERVICES COMMITTEE SUBCOMMITTEE – I WAS ON CAPITOL HILL ON WEDNESDAY TO TESTIFY BEFORE THE HOUSE FINANCIAL INSTITUTIONS SUBCOMMITTEE ON WAYS TO DEPOLITICIZE AND BRING TRANSPARENCY TO THE BUREAU OF CONSUMER FINANCIAL PROTECTION. AS I MENTIONED BEFORE THE COMMITTEE, CBA AND OUR MEMBERS SUPPORT THE MISSION OF THE BUREAU. THERE ARE...June 6, 2018On Wednesday, June 6, 2018, the House Financial Services Subcommittee on Financial Institutions and Consumer Credit held a hearing on improving transparency and accountability at the Bureau of Consumer Financial Protection. In the Bureau’s Semi-Annual Report to the President and Congress in April, Acting Director Mulvaney requested that Congress enact four changes to establish greater...