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Last week, the Federal Reserve Board published a paper on partnerships between community banks and fintech companies, “Community Bank Access to Innovation through Partnerships.”  The Fed’s publication of the paper is another indication of the increased attention that regulators are paying to bank relationships with fintechs.  It follows the publication at the end of last…

The OCC, FDIC, and Federal Reserve Board have issued a guide that is intended to assist community banks in conducting due diligence when considering relationships with financial technology (fintech) companies (Guide).

The issuance of the Guide follows the agencies’ July 2021 release of proposed interagency guidance for banking organizations on managing risks associated with third-party…

Last week, the OCC, Federal Reserve Board, and FDIC issued proposed guidance for banking organizations on managing risks associated with third-party relationships, including those with financial technology-focused entities such as bank/fintech sponsorship arrangements.  The agencies have made clear that if banks have ineffective risk management processes, agency examiners will closely scrutinize their third-party risk management…

Mr. Dougherty recently authored an article calling for the OCC’s abolishment and merger into the Federal Deposit Insurance Corp.  After reviewing the history of the creation of the OCC and Federal Reserve Banks, we examine and debate Mr. Dougherty’s arguments in support of his position.  We also discuss and respond to Mr. Dougherty’s criticism of…

The Board of Governors of the Federal Reserve System recently issued and invited public comment on proposed guidelines to be used by Federal Reserve Banks to evaluate requests for master accounts and/or access to Federal Reserve Bank (Fed) financial services, in order to support a more “transparent and consistent” approach to such requests.

Access to…

The Fed, FDIC, and OCC have issued a “Statement on Reference Rates for Loans” that addresses replacement rates for the London Inter-Bank Offered Rate (LIBOR).  LIBOR, which many creditors currently use as the index for calculating the interest rate on credit cards and other variable-rate consumer credit products, is expected to be discontinued…

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…

The Federal Reserve Board recently issued a Service Announcement setting forth the details of its FedNow Service, a new 24x7x365 interbank settlement service with clearing functionality to support instant payments in the United States.

The Fed announced its decision to develop the FedNow Service in a notice and request for comment issued in August 2019. …