The Bank Policy Institute (“BPI”) has issued its comment on the Federal Functional Regulators’ (the OCC, the Board of Governors of the Federal Reserve System, the FDIC, and the National Credit Union Administration) notice of proposed rulemaking (“NPRM”) to modernize financial institutions’ anti-money laundering and countering terrorist financing (“AML/CFT”) programs (“Comment”).… Continue Reading
CFPB/Fed/OCC increase exemption thresholds for appraisal requirement, Regs Z and M
The CFPB, Fed, and OCC have announced that they are increasing exemption thresholds that are subject to annual inflation adjustments. Effective January 1, 2025 through December 31, 2025, these exemption thresholds are increased as follows:
- The 2025 threshold for higher-priced mortgage loans that are subject to special appraisal requirements will increase from $32,400 to $33,500.
This week’s podcast episode: Regulators Escalate Focus on the Risks of Bank Relationships with Fintechs and Other Third Parties
On July 25, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies) issued a “Joint Statement on Banks’ Arrangements with Third Parties to Deliver Bank Deposit Products and Services” to “note potential risks related to arrangements between banks and third parties to deliver bank deposit products and services to end users”.… Continue Reading
FDIC, OCC and Justice Department update bank merger guidelines
The FDIC, the OCC and the Justice Department earlier this month issued updated standards for bank mergers. The three agencies acted separately, although officials noted that they had worked with the other agencies involved.
“Continued engagement with our fellow regulators is vitally important, especially as it relates to evaluating the competitive effects of mergers,” FDIC Chairman Martin Gruenberg said.… Continue Reading
Financial Regulators Propose Standards to Promote Interoperability of Data
On August 2, 2024, the CFPB, the OCC, the Federal Reserve Board, the FDIC, the NCUA, the FHFA, the CFTC, the SEC and the Treasury Department proposed a joint rule intended to establish standards to promote the ability of each of the agencies to exchange and use the data that the other agencies collect (referred to as the “interoperability” of financial data across the agencies).… Continue Reading
Acting Comptroller Hsu pressured to repeal preemption regs by Conference of State Bank Supervisors and consortium of consumer groups
On July 19, we blogged about comments Acting Comptroller Hsu made before the Exchequer Club on July 17 particularly his decision to review prior OCC preemption determinations in light of the Supreme Court’s recent opinion in Cantero v. Bank of America reversing the Second Circuit’s holding that a New York State law which requires the payment of 2% interest on mortgage escrow accounts is preempted because such law exercises control over a federal power, regardless of the magnitude of its effects.… Continue Reading
Banking Regulators Seek Comment on Third-Party Relationships with Financial Institutions
The federal banking regulators are seeking comment to better understand the relationship between financial institutions and third parties that work for them.
The OCC, Federal Reserve and FDIC “seek public comment to build on their understanding of these arrangements, including with respect to roles, risks, costs, and revenue allocation,” the agencies said.… Continue Reading
Regulators Outline Risks that Third-Party Servicers Pose to Banks
Banking regulators have issued a joint statement outlining the potential risks that financial institutions face in arrangements with third parties to deliver bank deposit products and services and examples of risk management practices to manage such potential risks.
The joint statement does not establish new expectations for financial institutions, the regulators said.… Continue Reading
Federal Banking Agencies Issue NPRM Consistent with FinCEN’s AML/CFT Modernization Proposal
The federal banking agencies, including 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 notice of proposed rulemaking (“Agencies’ NPRM”) to modernize financial institutions’ anti-money laundering and countering terrorist financing (“AML/CFT”) programs.… Continue Reading
OCC to review its preemption interpretations in light of Supreme Court opinion and state debanking laws
On July 17, Acting Comptroller of the Currency Michael Hsu delivered prepared remarks before the Exchequer Club entitled “Size, Complexity, and Polarization in Banking.”
These were his first public remarks about the Supreme Court’s recent opinion in Cantero v. Bank of America. In that case, the Court reversed a Second Circuit opinion which had held that because of preemption a national bank need not comply with a New York law which requires the payment of 2% interest on residential mortgage escrow accounts.… Continue Reading