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On April 4, acting Comptroller of the Currency Michael J. Hsu provided his remarks for the second year in a row at the Just Economy Conference hosted by the National Community Reinvestment Coalition. He focused his remarks on the latest developments of the Office of the Comptroller of the Currency (OCC) in its continuing efforts to elevate fairness in the financial industry.… Continue Reading

On February 5, 2024, several national and Texas banking and business trade groups (Plaintiffs) filed a lawsuit challenging the final regulations (Final Rules) implementing the Community Reinvestment Act of 1977 (CRA) that were jointly adopted in October 2023 by the Office of the Comptroller of the Currency, Federal Deposit Insurance Corporation, and Federal Reserve Board (Agencies).… Continue Reading

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 27, 2024, the U.S. Supreme Court heard oral argument in Cantero v. Bank of America, N.A., a case involving the effect of the Dodd-Frank Act on scope of preemption under the National Bank Act (NBA).  The specific question before the Court is whether, post-Dodd-Frank, the NBA preempts a New York statute requiring banks to pay interest on mortgage escrow accounts. … Continue Reading

The oral argument in Cantero v. Bank of America, N.A. will be heard on Tuesday, February 27 before the US Supreme Court. The Court recently granted the unopposed motion of the Solicitor General to participate in the oral argument. The Solicitor General will be taking 10 minutes of the oral argument time allocated to the Petitioners.… Continue Reading

Several national and Texas banking and business trade groups have filed a lawsuit in the U.S. District Court for the Northern District of Texas challenging the final regulations (Final Rules) implementing the Community Reinvestment Act of 1977 (CRA) that were jointly adopted in October 2023 by the Office of the Comptroller of the Currency, Federal Deposit Insurance Corporation, and Federal Reserve Board (Agencies). … Continue Reading

The scope of national bank preemption is currently before the U.S. Supreme Court in Cantero v. Bank of America, N.A.  A New York statute requires the payment of interest on mortgage escrow accounts and the question before the Supreme Court is whether the National Bank Act (NBA) preempts application of the New York statute to national banks. … Continue Reading

Bank of America, N.A. has filed its merits brief in Cantero v. Bank of America, N.A., the case currently before the U.S. Supreme Court dealing with the scope of national bank preemption.  The petitioners must file their reply brief by February 16, 2024.  (The petitioners’ merits brief is available here.) … 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

On February 27, 2024, the U.S. Supreme Court will hear oral argument in Cantero v. Bank of America, N.A., a case involving the scope of preemption under the National Bank Act (NBA).  The question before the Court is whether the NBA preempts a New York statute requiring banks to pay interest on mortgage escrow accounts. … Continue Reading