Regulatory Compliance & Agency Engagement

  • October 29, 2020
    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...
  • October 27, 2020
    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...
  • October 20, 2020
    Dear Mr. Feldman: The Consumer Bankers Association (“CBA”) appreciates the opportunity to respond to the Federal Deposit Insurance Corporation’s (“the FDIC” or “the Agency”) notice and request for comment (“the Proposal”) regarding revisions to the agency’s Guidelines for Appeals of Material Supervisory Determinations (“Guidelines”). We applaud the FDIC’s efforts to enhance the independence of...
  • October 20, 2020
    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...
  • October 19, 2020
    CBA Statement on FDIC Unbanked Survey Results WASHINGTON – Consumer Bankers Association President and CEO Richard Hunt issued the following statement after the Federal Deposit Insurance Corporation (FDIC) released results of a survey revealing a record number of American households with bank accounts in 2019: “The nation’s banks are well-capitalized, well-positioned and committed to ensuring...
  • October 14, 2020
    Consumer Financial Protection Bureau Settles With Nissan Motor Acceptance Corporation For Illegal Collections And Repossession Practices On Tuesday, October 13, 2020, the Bureau issued a press release regarding a consent order against Nissan Motor Acceptance Corporation (Nissan), an auto financing subsidiary of Nissan North America, Inc., which services auto loans and leases originated by Nissan...
  • October 14, 2020
    Federal Reserve requests public comment on technical, clarifying updates regarding the Federal Open Market Committee’s Rules Regarding Availability of Information, which describe its Freedom of Information Act (FOIA) procedures On Wednesday, October 14, 2020, the Federal Reserve issued a press release requesting public comment on technical, clarifying updates regarding the Federal Open Market...
  • October 14, 2020
    OCC Assesses $85 Million Civil Money Penalty Against USAA On Wednesday, October 14, 2020, the OCC issued a press release about the assessed $85 million civil money penalty against USAA, Federal Savings Bank. The OCC took this action based on the bank’s failure to implement and maintain an effective compliance risk management program and an effective information technology risk governance program...
  • October 5, 2020
    Overall, though, lobbyists said they would expect a diverse mix of progressives and moderates, even though few are likely to come straight from Wall Street. "I don't think you'll see the progressive liberals getting all the appointments they want," said Richard Hunt, CEO of Washington group the Consumer Bankers Association. Biden's campaign, which did not immediately comment, has said he plans to...
  • August 25, 2020
    CBA Statement on FDIC Quarterly Banking Report WASHINGTON, D.C. – Consumer Bankers Association President and CEO Richard Hunt issued the following statement on the Federal Deposit Insurance Corporation’s quarterly banking profile: “The FDIC’s latest quarterly report is another sign of the banking industry’s strength throughout the COVID-19 pandemic. Banks of all sizes have joined together to...

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