CFPB, Federal Agencies, State Agencies, and Attorneys General
On June 10, 2024, the Connecticut Department of Banking (“Department”) issued guidance (the “Guidance”) to give direction on required consumer-like disclosures in certain commercial financing offers.
As background on the Guidance, Connecticut’s commercial financing disclosure law, An Act Requiring Certain Disclosures, was signed into law on June 28 2023, and will become effective on July 1, 2024 (the “Statute”).… Continue Reading
The results are in after the closing of a public comment period related to the Federal Deposit Insurance Corp.’s review of its bank merger policies. The request for information (RFI) included questions related to the agency’s current bank merger review process, and how the process could be improved. One issue raised in the RFI is “to what extent should the CFPB be consulted by the FDIC when considering the convenience and needs factor and should that consultation be formalized?”… Continue Reading
On Monday, September 9, 2019, a group of 28 housing, consumer protection and community development organizations issued a letter to the Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency and Federal Reserve Board in advance of an anticipated Notice of Proposed Rulemaking regarding the Community Reinvestment Act (“CRA”) and in response to an Advance Notice of Proposed Rulemaking published in August 2018 (the “ANPR”).… Continue Reading
On Tuesday, the FDIC released a Notice of Proposed Rulemaking (NPR) that outlines anticipated revisions to its regulations regarding interest rate restrictions that apply to less than well capitalized insured depository institutions. The proposed rule modifies the methodology by which the national rate and national rate cap are calculated on deposit products and proposes a new methodology for calculation of a local rate.… Continue Reading
