Scott A. Coleman

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This is our third blog post on the final rule issued on October 24, 2023 by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency amending their regulations implementing the Community Reinvestment Act (“CRA”) (the “Final Rule”). … Continue Reading

This is our second blog post on the final rule issued on October 24, 2023 by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency amending their regulations implementing the Community Reinvestment Act (“CRA”) (the “Final Rule”). … Continue Reading

On October 24, 2023,  the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency issued a final rule amending their regulations implementing the Community Reinvestment Act (“CRA”) (the “Final Rule”).  The Final Rule marks the first substantial revision to the CRA regulations in nearly thirty years. … Continue Reading

On November 2, 2023, the Consumer Financial Protection Bureau issued a report on the community reinvestment laws of seven states (Connecticut, Illinois, Massachusetts, New York, Rhode Island, Washington, West Virginia), and the District of Columbia that evaluate the record of state-chartered financial institutions and other lenders in meeting the credit needs in their communities.… Continue Reading

On October 24, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation issued a final rule amending their regulations implementing the Community Reinvestment Act.  Although the final rule is effective April 1, 2024, the compliance date for the majority of the rule’s provisions is January 1, 2026. … Continue Reading

At its open Board meeting scheduled for October 24, 2023, the Federal Reserve Board is expected to approve its final rule amending its current regulation implementing the Community Reinvestment Act.  The Federal Deposit Insurance Corporation is expected to approve its final CRA rule at the meeting of its Board of Directors also scheduled for October 24.… Continue Reading

The Federal Reserve, FDIC, and OCC have released final interagency guidance for their respective supervised banking organizations on managing risks associated with third-party relationships, including relationships with financial technology-focused entities such as bank/fintech sponsorship arrangements.  The guidance is intended to provide principles for effective third-party risk management for all  types of third-party relationships, regardless of how they may be structured.  … Continue Reading

The OCC has issued a new bulletin and the FDIC has issued new supervisory guidance directed to their supervised institutions to address “authorize positive, settle negative” (APSN) overdraft  fee practices.  The OCC bulletin also addresses non-sufficient funds (NSF) fee practices.  Based on the bulletin and guidance, it would appear that the OCC and FDIC share the CFPB’s apparent view that APSN fees are unfair regardless of how clearly and conspicuously they are disclosed to consumers. … Continue Reading

On March 30, 2023, the White House endorsed several proposals to strengthen regulatory requirements for the banking industry in the wake of the Silicon Valley Bank and Signature Bank failures. This comes on the heels of President Biden’s March 13, 2023 remarks where he noted his intention to ask Congress and the banking regulators to “strengthen the rules for banks” to decrease the likelihood of similar failures in the future.… Continue Reading

The U.S. Supreme Court has invited the Solicitor General to file briefs expressing the views of the United States in two cases involving the question whether state laws requiring the payment of interest on mortgage escrow accounts are preempted for national banks and federal savings associations.  The Supreme Court is considering whether to grant the petitions for certiorari filed in the two cases.… Continue Reading