The OCC and FDIC have issued a joint proposal to revise their regulations implementing the Community Reinvestment Act (CRA).  Although the Federal Reserve, OCC and FDIC, are the primary CRA regulators, the Fed did not join the proposal and presumably will issue a separate proposal.  Comments on the proposal are due by March 9, 2020.

The OCC, Federal Reserve Board, FDIC, NCUA and CFPB have issued an “Interagency Statement on the Use of Alternative Data in Credit Underwriting.”

The statement sets forth the agencies’ recognition of the benefits of using alternative data (AD) in credit decisions.  For purposes of the statement, AD means “information not typically found in

On October 10, 2019, the Board of Governors of the Federal Reserve System (Board), together with the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation, adopted a final rule to revise the criteria for determining the applicability of regulatory capital and liquidity requirements for large U.S. banking organizations and the

As we previously reported, last November the FDIC, Federal Reserve Board and Comptroller of the Currency (the federal banking agencies) proposed a rule to implement a rural residential property appraisal exemption under the Economic Growth, Regulatory Relief, and Consumer Protection Act (the Growth Act) and also increase the appraisal exemption based on transaction value

The Republican members of the House Financial Services Committee have sent a letter to Comptroller of the Currency Joseph Otting urging the OCC to make action to address the uncertainty created by Second Circuit’s Madden decision “a priority on the OCC’s rulemaking agenda.” 

In Madden, the Second Circuit ruled that a purchaser of charged-off

I don’t understand why Professor Levitin is attacking the OCC and FDIC for filing an amicus brief in an “obscure small business bankruptcy case to which a bank was not even a party.”  The brief was an exceptional piece of drafting and analysis and the banking agencies do not deserve to be denigrated for a

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

The OCC and FDIC have filed a joint amicus brief in a Colorado federal district court arguing that the court should affirm the decision of a bankruptcy court holding that a non-bank loan assignee could charge the same interest rate the bank assignor could charge under Section 27(a) of the Federal Deposit Insurance Act, 12

In this podcast, we discuss the FDIC’s observations about its “most salient” consumer compliance exam findings during 2018, including issues relating to Overdraft Programs, Real Estate Settlement Procedures Act (“RESPA”) Section 8, Regulation E, “Skip-A-Payment” or Deferment Loan Programs, and Lines of Credit.

Click here to listen to the podcast.