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Impact of Covid-19 Felt in the Shared National Credit Reviews Released by Bank Regulators

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.” SNC (pronounced like the candy bar but without the “ers”) stands for the Shared National Credit Program, which, since 1977, has assessed risk in the largest and most complex credits shared by multiple regulated financial institutions. As shown in the table below, the reviewed 2020 SNC loans totaled $5.1

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FDIC announces new resources for brokered deposits regulation

CFPB Monitor

On April 1, 2021, the FDIC’s final rule issued in December 2020 revising its brokered deposits regulation became effective. The final rule also requires a third party relying on either of two Designated Exceptions (referred to as the “25 percent test” and the “enabling transactions test”) to provide written notice to the FDIC.

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OCC Highlights, AML & CRA Risks

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Additionally, the recent rule by the OCC, the Federal Reserve, and the FDIC strengthens and modernizes Community Reinvestment Act (CRA) regulations. The effective date of the new rule is April 1, 2024, with key provisions taking effect on January 1, 2026, and January 1, 2027. 

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OCC and FDIC extend comment period for proposed amendments to CRA rules

CFPB Monitor

The OCC and FDIC announced yesterday that they have extended the 60-day comment period for their joint proposal to revise their regulations implementing the Community Reinvestment Act that was published in the Federal Register on January 8, 2020. As extended by 30 days, the comment period ends on April 8, 2020.

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OCC and FDIC issue proposed rules to undo Madden

CFPB Monitor

The OCC and FDIC issued proposed rules this week intended to eliminate the uncertainty created by the Second Circuit’s decision in Madden v. Comments on the OCC’s proposal must be submitted by January 21, 2020. With regard to interest rate authority, the OCC points to Section 85 (applicable to national banks) and 12 U.S.C.

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Seven states and D.C. file lawsuit challenging FDIC “Madden fix” rule

CFPB Monitor

The plain language of the governing federal statute applies only to interest that an FDIC-insured state bank may charge. Allegedly, the FDIC’s rule represents an expansion of the FDIA’s preemption of state law interest rate caps by extending the preemption to assignees of loans originated by such banks.

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OCC CRA Final Rule: What’s Next for the FDIC and Federal Reserve Board?

CFPB Monitor

When the OCC issued its final Community Reinvestment Act (“CRA”) rule on May 20, 2020, the agency acted alone without waiting to achieve consensus with the FDIC, the agency with which the OCC had jointly issued its proposed rule. As to the Federal Reserve Board (“FRB”), it had already bowed out of the CRA reform effort in 2019.

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