On March 28, 2024, the Financial Crimes Enforcement Network (FinCEN), in consultation with the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Board of Governors of the Federal Reserve System, issued a request for information (RFI).

The RFI seeks information and comment regarding the Customer Identification Program (CIP) Rule requirement that banks collect a full Social Security number (SSN) prior to account opening from a customer who is an individual and a U.S.… Continue Reading

On February 6, 2024, National Credit Union Administration (NCUA) Chairman Todd M. Harper spoke at a Brookings Institution event to outline his regulatory agenda and supervisory priorities for 2024. His prepared remarks addressed the 90th Anniversary of the Federal Credit Union Act, credit union performance in third quarter of 2023, risks posed by third party service providers, liquidity management, and consumer financial protection.… Continue Reading

On July 6, the Financial Crimes Enforcement Network (“FinCEN”), the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency (collectively, “the Agencies”) issued a Joint Statement to “remind” banks that they, of course, should apply a risk-based approach to assessing customer relationships and conducting customer due diligence (“CDD”).… Continue Reading

In the latest demonstration that there’s a “new CFPB” as well as other new regulatory sheriffs in town, the CFPB, the federal banking agencies (OCC, FDIC, Federal Reserve Board, and NCUA), and state financial regulators issued a joint statement yesterday to announce that they will no longer provide “supervisory and enforcement flexibility” to mortgage servicers in meeting compliance requirements. … Continue Reading

The CFPB, Federal Reserve Board, FDIC NCUA, OCC, in conjunction with the state bank and state credit union regulators, jointly issued a statement on managing the transition away from LIBOR (Joint Statement).

In 2017, the United Kingdom’s Financial Conduct Authority (FCA), the regulator that oversees the panel of banks on whose submissions LIBOR is based, announced that it would discontinue LIBOR sometime after 2021.… Continue Reading

On May 19, 2021, the House Financial Services Committee will hold a hearing, “Oversight of Prudential Regulators: Ensuring the Safety, Soundness, Diversity, and Accountability of Depository Institutions.”  The scheduled witnesses are:

  • Todd Harper, Chairman, National Credit Union Administration
  • Michael Hsu, Acting Comptroller of the Currency, Office of the Comptroller of the Currency
  • Jelena McWilliams, Chairman, Federal Deposit Insurance Corporation
  • Randal Quarles, Vice Chairman of Supervision, Board of Governors of the Federal Reserve System

Acting Comptroller Hsu is expected to be questioned about the OCC’s Community Reinvestment Act rule, its special purpose national bank charter for nondepository companies, and its fair access rule. … Continue Reading

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. … Continue Reading

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 by June 1, 2021.… Continue Reading

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 requesting a formal rulemaking on the subject. … Continue Reading

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:

  • Brian Brooks, Acting Comptroller of the Currency
  • Randal Quarles, Vice Chairman of Supervision, Federal Reserve Board
  • Rodney Hood, Chairman, NCUA
  • Jelena McWilliams, Chairman, FDIC
Continue Reading