Our special guest is Zarik Khan, Founder of Finsolute Advisors.  In October 2023, the Federal Reserve Board issued a proposal to lower the maximum interchange fee that a large debit card issuer can receive for a debit card transaction.  We first look at the roles of the various parties involved in a typical transaction in which a consumer uses a debit card to make a purchase from a merchant and the various fees imposed in connection with the transaction. … Continue Reading

The Board of Governors of the Federal Reserve (the “Board”) has announced that it is extending the comment period for its proposed changes to its debit card interchange fee rule until May 12, 2024. Comments were originally due on February 12, 2024.

On October 25, 2023, the Board issued a Notice of Proposed Rulemaking for Regulation II.… Continue Reading

On September 18, 2023, the Federal Reserve, Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency jointly published and sought comments on a proposal to implement new, standardized capital requirements that would, among other things, increase capital requirements for banks with $100 billion or more in total assets.… Continue Reading

The U.S. Supreme Court has scheduled oral argument for Tuesday, February 20, 2024 in Corner Post, Inc. v Board of Governors of the Federal Reserve System. The question that the Supreme Court will decide is when a right of action first accrues for an Administrative Procedure Act (APA) Section 702 challenge to a final rule issued by a federal agency—when the final rule is issued or when the rule first causes injury.… Continue Reading

On October 24, 2023, the OCC, FDIC and Board of Governors of the Federal Reserve System jointly adopted final amendments to their regulations implementing the Community Reinvestment Act of 1977 (CRA).  In this episode, which repurposes a webinar, we are joined by guest speaker Kenneth H. Thomas, Ph.D., Founder/CEO of Community Development Fund Advisors.  … Continue Reading

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

As we previously blogged, the Board of Governors of the Federal Reserve (the “Board”) held an open meeting on October 25, 2023 to discuss the debit card interchange fee cap. The debit card interchange fee cap was part of the so-called “Durbin Amendment” to the Dodd-Frank Act, which required the Board to promulgate a regulation applicable to banks having more than $10 billion in assets establishing maximum debit card interchange fees that are “reasonable and proportional to the actual cost” of processing the transaction.… 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