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Regulatory Compliance & Agency Engagement
- August 22, 2018On Wednesday, August 22, 2018, the Federal Reserve Board, FDIC and OCC issued a press release regarding an interim final rule amending the agencies' liquidity rules to treat certain eligible municipal securities as high-quality liquid assets, as required by the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018 (EGRRCPA). The EGRRCPA requires the agencies to treat a municipal...August 20, 2018August 20, 2018 VIA Electronic Submission Regulations Division Office of General Counsel Department of Housing and Urban Development 451 7 th Street SW Room 10276 Washington, DC 20410 Re: Reconsideration of HUD’s Implementation of the Fair Housing Act’s Disparate Impact Standard; Advance Notice of Prosed Rulemaking; Docket No. FR-6111-A-01 RIN 2529-ZA01 Dear Sir or Madam: The Consumer Bankers...August 10, 2018D.C. DOWNLOAD Couldn’t Make the Membership Call? Here’s What You Missed - CBA held a membership call yesterday to offer an update on all things D.C. – ranging from BCFP rulemaking and OCC priorities to the latest updates on CRA, the midterm elections and CBA news. If you missed the call, here is a quick recap: Bureau of Consumer Financial Protection The Senate Banking Committee had scheduled a...July 20, 2018CBA UPDATE Back to School: CBA Banking School Kicks Off - CBA kicks off our Executive Banking School this weekend at Furman University. We strive to make CBA EBS the go-to place for banks’ rising stars and word is out. The freshman class is nearly 140 strong and we will have close to 100 graduates this year. Traveling to Furman to meet with our banking “students” is an annual highlight as is our...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 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...