CFPB, Federal Agencies, State Agencies, and Attorneys General
Last month, the Federal Reserve Board announced its plans to develop a real-time payments (RTP) service to be offered by the Federal Reserve Banks to directly support faster payments.
Three members of Ballard Spahr’s Consumer Financial Services Group with extensive experience negotiating complex payments transactions for some of the world’s largest retailers and financial institutions…
The Federal Reserve Board has determined that the Federal Reserve should take the following two actions:
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The Federal Reserve Board has published in the Federal Register a notice of proposed rulemaking with request for comment on a proposal to simplify and increase transparency of its rules for determining control of a banking organization. The proposal’s comment period closes on July 15, 2019.
The proposed revisions to the Board’s control regulations would…
The FDIC and the Federal Reserve Board of Governors issued a joint advisory to make financial institutions aware of a 2018 amendment to the Fair Credit Reporting Act that provides that a financial institution may, but is not required, to offer a loan rehabilitation program (Section 602 Program) to private education loan borrowers whose credit…
Last July, the OCC announced its decision to accept applications for special purpose national bank (SPNB) charters from fintech companies. At that time we observed that, while not discussed in the materials released by the OCC, it appeared that a fintech company holding an SPNB charter would be required to be a member of…
On November 20, the Federal Reserve Board (FRB) and CFPB jointly proposed amendments to Reg. CC, which implements the Expedited Funds Availability Act (EFA Act), and also reopened for public comment various amendments that the FRB had proposed in March of 2011. This new proposal is in addition to the amendments to Reg.
The American Bankers Association and the Bank Policy Institute have sent a letter to the Board of Governors of the Federal Reserve System (Fed) to petition the Fed to engage in rulemaking to clarify the Fed’s September 2018 “Interagency Statement Clarifying the Role of Supervisory Guidance” (the “Interagency Statement”). The Interagency Statement was…
Earlier this month, the Federal Reserve invited comment on actions it can take “to promote ubiquitous, safe, and efficient faster payments in the United States by facilitating real-time interbank settlement of faster payments.” Comments are due by December 14, 2018.
More specifically, the Fed is seeking comment on two potential actions. One action is the…
Last Wednesday the Federal Reserve published approved final amendments to Regulation CC (Availability of Funds and Collections of Checks) which update the liability provisions of Reg. CC to address the nearly-complete conversion of the nation’s check collection system from a paper to an electronic environment.
Historically, when banks disputed which party should be responsible for…
Creditors currently using the London Inter-Bank Offered Rate (LIBOR) as the index for variable-rate consumer loans should note that the Federal Reserve Bank of New York is now publishing a new index named the Secured Overnight Financing Rate (SOFR).
SOFR is intended to take the place of LIBOR when LIBOR is discontinued (as the United…
