OCC

OCC Publishes Guidance on Substantial Asset Changes

On August 23, 2017, the Office of the Comptroller of the Currency (OCC) published guidance on filings required by national banks and federal savings associations (collectively referred to here as “banks”) pertaining to “substantial asset changes.”  The guidance lists various events that are considered substantial asset changes for which banks must…

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OCC Issues Mortgage Lending Bulletin Concerning High-LTV Loans

On August 21, 2017, the Office of the Comptroller of the Currency (OCC) issued Bulletin 2017-28, providing risk management guidance to lenders offering residential mortgage loans with loan-to-value (LTV) ratios that exceed 100 percent at origination (“high-LTV loans”) in connection with community redevelopment programs. Since the onset of the financial crisis,…

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Payday Lenders Claim Regulators Are Choking Their Livelihoods in Motion for Preliminary Injunction

On November 23, 2016, Advance America, Inc., a payday lender, and Community Financial Services Association of America, Ltd., a trade organization which represents the interests of payday lenders (Plaintiffs), filed a Motion for Preliminary Injunction (Motion) against the Federal Deposit Insurance Corporation, the Office of Comptroller of the Currency, and the…

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OCC to Create New "Office of Innovation"

At the end of October, the Office of the Comptroller of the Currency (“OCC”) released its Recommendations and Decisions for Implementing a Responsible Innovation Framework (the “Recommendations”).  The Recommendations are the latest step in a long process the OCC has undertaken to try to revamp its approach to new financial…

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OCC Hosts Forum on Responsible Innovation

On June 23, 2016, the Office of the Comptroller of the Currency (OCC) hosted a daylong forum, “Supporting Responsible Innovation in the Federal Banking System.” The purpose of the forum was to encourage a dialogue among stakeholders about what framework the OCC should adopt to encourage responsible innovation and provide…

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OCC Introduces Framework for Responsible Innovation

On March 31, 2016 the Office of the Comptroller of the Currency (OCC) issued a white paper setting forth its vision of responsible innovation, and signaling its increasing involvement in the financial technology (Fintech) space.  The white paper, titled “Supporting Responsible Innovation in the Federal Banking System: An OCC Perspective,”…

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2Q 2015 Sees Increase in Enforcement Litigation

*Editor’s Note:  This post originally appeared on our sister blog, Consumer Finance Enforcement Watch.  Visit CFEW for more real-time reporting on the full range of public federal and state consumer finance enforcement activity.* For the second quarter of 2015, Consumer Finance Enforcement Watch tracked 56 enforcement actions taken against consumer finance providers,…

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The CFPB Targets Lender's Credit Card Division With More Than $200MM In Penalties

The Consumer Financial Protection Bureau (CFPB) has set its sights on debt collection practices again.  In April, we wrote about the CFPB’s $63 million settlement with a mortgage servicer, Green Tree Mortgage, in part for Green Tree’s alleged treatment of mortgage debt.  On July 8, 2015, the CFPB once again demonstrated it was…

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Add-On Products Continue To Present Litigation Risks For Lenders

The Consumer Financial Protection Bureau’s recent action against two credit card vendors regarding credit monitoring and identity theft protection services is a reminder of the legal risks associated with certain add-on products. The July 1 settlement, in which the CFPB found that the vendors misled customers about the benefits of…

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OCC, FRB, and FDIC Push Ahead on Reducing Regulation of Community Banks

On May 4, 2015, Comptroller of the Currency Thomas Curry, Federal Reserve Board (FRB) Governor Daniel Tarullo, and Federal Deposit Insurance Corporation (FDIC) Chairman Martin Gruenberg held the third in a series of outreach meetings to discuss with the public their efforts to reduce the regulatory burden on community banks…

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Interagency Guidance: Regulators Will Enforce UDAAP Laws Notwithstanding Repeal of Regulation AA

The Federal Reserve Board recently made headlines when it repealed its Regulation AA to comply with the Dodd-Frank Act, leading some to wonder how, and to what extent, regulation of financial institutions might change going forward. But the federal agencies charged with regulating banking and credit activities have made it clear that they will continue to enforce prohibitions…

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Committee of Banking Regulators Begins Cyber-Security Assessments of 500 Financial Institutions

On June 24, 2014, in response to the “increasing volume and sophistication of cyber threats,” the Federal Financial Institutions Examination Council (“FFIEC”) began a month-long cyber-security assessment of 500 community financial institutions and credit unions.  Announcing what it dubbed a “pilot program,” the FFIEC—a formal, interagency body made up of…

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