On October 29, 2020, five federal financial regulatory agencies, the FRB, CFPB, FDIC, NCUA and the OCC (the “Agencies”), jointly issued a proposed rule outlining and confirming the Agencies’ use of supervisory guidance for regulated institutions. The proposed rule intends to codify the Agencies’ Interagency Statement Clarifying the Role of…
Read More »On Friday, July 31, 2020, Founding Partner Jim Noonan will be virtually presenting at this year’s American Legal & Financial Network (ALFN) ANSWERS webinar entitled “Hindsight is 2020 – A year in Review. Top Issues of the Past Year.” Conferences as we have known them may be on hold, but…
Read More »On June 2, 2020, the Office of the Comptroller of the Currency (“OCC”) issued a final rule (“Rule”) to quell the uncertainty created by the Second Circuit decision in Madden v. Midland Funding, LLC, 786 F.3d 246 (2d Cir. 2015) for national banks and federal savings associations (“banks”) engaged in…
Read More »On October 20, 2017, the OCC issued Bulletin 2017-49 providing updated principles that OCC regulated banks should follow to prudently manage the risks associated with offering new, modified, or expanded products and services (“New Activities”). According to the bulletin, New Activities should be developed and implemented consistently with sound risk…
Read More »On August 22, 2017, the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation have issued a joint proposed rule to extend the current transitional capital rules treatment of certain regulatory capital deductions and risk weights and certain minority interest…
Read More »On June 26, 2017, the FDIC has issued FIL-30-2017 concerning its update to the Affordable Mortgage Lending Guide (“Guide”) with updated Part II information concerning mortgage programs offered through state housing finance agencies (HFAs). The updated Guide contains a state-by-state HFAs product matrix, program summaries and quick links. It also…
Read More »On May 23, 2017, the OCC issued a bulletin providing updated guidance to national banks, including community banks, concerning changes to OCC’s policies and procedures regarding violations of laws and regulations. This updated guidance is effective July 1, 2017. The new guidance goals are to: (i) standardize a process for…
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