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Recently, federal agencies proposed revisions to the Interagency Questions and Answers Regarding Flood Insurance.  The agencies are the Comptroller of the Currency, Farm Credit Administration, FDIC, Federal Reserve Board, and National Credit Union Administration (Agencies).  The proposed Q&As will supplement the proposed Q&As issued by the Agencies in July 2020.  Those proposed Q&As contained…

In what could be an important step towards needed regulatory updating to accommodate the growing use of artificial intelligence (AI) by financial institutions, the CFPB, FDIC, OCC, Federal Reserve Board, and NCUA issued a request for information (RFI) regarding financial institutions’ use of AI, including machine learning (ML).  Comments on the RFI must be received…

The CFPB, OCC, FDIC and NCUA have issued substantially similar final rules on the role of supervisory guidance.  The final rules adopt the agencies’ proposals without substantive change.

In September 2018, the agencies issued an “Interagency Statement Clarifying the Role of Supervisory Guidance.”  In response to the Statement, the agencies received a petition…

On November 10, the Senate Banking Committee will hold a hearing, “Oversight of Financial Regulators.”

On November 12, the House Financial Services Committee will hold a hearing, “Oversight of Prudential Regulators: Ensuring the Safety, Soundness, Diversity, and Accountability of Depository Institutions during the Pandemic.”

The scheduled witnesses at both hearings are:…

The CFPB, OCC, Federal Reserve, FDIC, and NCUA have issued a proposed rule on the role of supervisory guidance.

In September 2018, the agencies issued an “Interagency Statement Clarifying the Role of Supervisory Guidance.”  In response to the Statement, the agencies received a petition requesting a formal rulemaking on the subject.  The proposed…

Regulators Provide Greater Transparency into BSA/AML Enforcement Process.  On August 13, 2020, the Federal Reserve System, Federal Deposit Insurance Corporation, National Credit Union Administration, and Office of the Comptroller of the Currency (the “Agency” or collectively the “Agencies”) issued a joint statement updating and clarifying their 2007 guidance regarding how they evaluate enforcement actions…

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…

The National Credit Union Administration has published a final rule in the Federal Register that amend the NCUA’s general lending rule to provide federal credit unions (FCU) with a second option for offering “payday alternative loans” (PALs).  The final rule is effective December 2, 2019.

In 2010, the NCUA amended its general lending rule to…

The National Credit Union Administration has published a notice in the Federal Register proposing to amend the NCUA’s general lending rule to provide federal credit unions (FCU) with a second option for offering “payday alternative loans” (PALs).  Comments on the proposal are due by August 3, 2018.

In 2010, the NCUA amended its general lending…

In addition to the CFPB’s Spring 2018 rulemaking agenda that we have already blogged about, the Spring 2018 rulemaking agendas of several other federal agencies contain some items of interest to consumer financial services providers.

Items of particular interest are:

  • OCC.  The OCC plans to issue an Advance Notice of Proposed Rulemaking “for modernizing

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