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
In furtherance of the Biden Administration’s “junk fee” agenda, on January 17, 2024, the Consumer Financial Protection Bureau issued its proposed rule to amend Regulations E and Z to regulate overdraft services provided by “very large financial institutions” (an insured depository institution or an insured credit union that has total assets of more than $10 Billion and any affiliate thereof, as determined under 12 U.S.C.… Continue Reading
The Federal Deposit Insurance Corporation (FDIC) recently issued a notice of proposed rulemaking (NPR) and request for information (RFI) addressing “False Advertising, Misrepresentation of Insured Status and Misuse of the FDIC’s Name or Logo”.
Under this NPR, the title of 12 CFR Part 328, currently “Advertisement of Membership” would be changed to “Advertisement of Membership, False Advertising, Misrepresentation of Insured Status, and Misuse of the FDIC’s Name or Logo.”… Continue Reading
As we previewed earlier this year, the CFPB, on June 15, proposed substantive changes to the Prepaid Final Rule (the “Rule”). The proposed changes are generally positive for prepaid providers and incorporate feedback and comments from industry representatives. The proposal, however, does not lift the onerous restrictions on credit features currently in the Rule. … Continue Reading
The proposed rule amending the Home Mortgage Disclosure Act and its implementing regulation, Regulation C, was published in the Federal Register today. As such, the official comment deadline will be October 29, 2014. We previously published a short description and analysis of the proposed rule that noted a different comment date.… Continue Reading
The CFPB issued a proposed rule amending Regulation C to expand data reporting requirements for mortgage industry participants. The proposed rule is 573 pages and our Mortgage Banking Group will analyze the proposal and work with clients on its impact. Comments are due on or before October 22, 2014.
Because of the absence of important loan and borrower data elements, HMDA data has long been recognized as providing for a less than robust assessment of mortgage lending activity. … Continue Reading