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On January 14, 2021, the NCUA and CFPB announced the agencies have entered into a memorandum of understanding relating to their joint supervision of federally insured credit unions over $10 billion in assets. The MOU seeks to “improve coordination, cooperation, and efficiency generally, and to reduce the burden to institutions and examination staff” by proactively sharing information and coordinating on examinations.… 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

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. … Continue Reading

The CFPB, OCC, FDIC, Federal Reserve, and NCUA have issued a joint statement “to specifically encourage” banks, savings associations, and credit unions “to offer responsible small-dollar loans to both consumers and small businesses” in response to the COVID-19 outbreak.  The statement builds on the March 19 statement issued jointly by the OCC, FDIC, and Federal Reserve on Community Reinvestment Act (CRA) consideration for activities in response to the outbreak.  … Continue Reading

The Subcommittee on Consumer Protection and Financial Institutions of the House Financial Services Committee has scheduled a hearing entitled “An Examination of Regulators’ Efforts to Preserve and Promote Minority Depository Institutions” on November 20, 2019.  In its first hearing on minority depository institutions, the Subcommittee examined the unique challenges facing MDIs and the communities they serve. … Continue Reading

The National Credit Union Administration has published a final rule in the Federal Register that amend the NCUA’s general lending rule to provide federal credit unions (FCU) with a second option for offering “payday alternative loans” (PALs).  The final rule is effective December 2, 2019.

In 2010, the NCUA amended its general lending rule to allow FCUs to offer PALs as an alternative to other payday loans. … Continue Reading

The National Credit Union Administration has published a notice in the Federal Register proposing to amend the NCUA’s general lending rule to provide federal credit unions (FCU) with a second option for offering “payday alternative loans” (PALs).  Comments on the proposal are due by August 3, 2018.

In 2010, the NCUA amended its general lending rule to allow FCUs to offer PALs as an alternative to other payday loans. … Continue Reading

In addition to the CFPB’s Spring 2018 rulemaking agenda that we have already blogged about, the Spring 2018 rulemaking agendas of several other federal agencies contain some items of interest to consumer financial services providers.

Items of particular interest are:

  • OCC.  The OCC plans to issue an Advance Notice of Proposed Rulemaking “for modernizing the current regulations to carry out the purposes of the Community Reinvestment Act.” 
… Continue Reading

As we reported in an earlier posting, it has taken considerable effort to locate the memoranda of understanding (MOUs) that the CFPB has put in place with various other federal agencies. More of those MOUs recently surfaced through, we believe, a Freedom of Information Act (FOIA) request. One of the newly uncovered MOUs is between CFPB and FinCEN and gives the CFPB direct electronic access to Bank Secrecy Act information collected in FinCEN’s Currency and Banking Retrieval System.… Continue Reading