CFPB Monitor

JULY 22, 2020

24, 1464(c), and 371, respectively) that allow national banks and federal savings associations to extend credit do not indicate how to determine when a bank has exercised such authority and, rather than its relationship partner, has made a loan. Presumably, we will soon see a proposed “true lender” rule from the FDIC.

National 78

National Lending Exercises FDIC 78

Jeff For Banks

AUGUST 2, 2014

Aside from the clear lack of analytic rigor you exercised to come to this conclusion, it is important to remind you that estimating future negative events that impact our capital is guesswork. bank regulation credit union regulation FDIC financial institution regulation Jeff Marsico Kafafian Group OCC regulation Schmidlap'

Regulation 90

Regulation DC FDIC Analytics 90

FICO

DECEMBER 20, 2018

The annual exercise of staring into our crystal balls and making predictions for the coming year has begun. In our current rising rate environment, any bank that can’t grow (or at least sustain) its deposits base will face shrinking net interest margins and a competitive disadvantage in their consumer lending businesses.

Trends 73

Trends Lending Fraud Exercises 73

CFPB Monitor

OCTOBER 6, 2022

Unless it settles, it creates a risk to the viability of bank model online lending that is structured like OppFi’s Program. It would be helpful if the FDIC were to submit an amicus brief supporting OppFi’s position regarding federal preemption of California usury law under Section 27(a) of the FDI Act.

California 78

California FDIC Analysis Utah 78

CFPB Monitor

SEPTEMBER 8, 2016

The Department of Defense (DoD) has issued an interpretive rule to assist the industry in complying with its July 2015 final rule amending the Military Lending Act’s implementing regulation. Several of those suggestions are noted below. Highlights of the interpretive rule include the following: Scope of purchase money exception.

Compliance 60

Compliance FDIC Security Regulation 60

CFPB Monitor

MAY 6, 2019

. § 520(e)(1), which contains a sentence that directly justifies the SPNB charter: “A special purpose bank that conducts activities other than fiduciary activities must conduct at least one of the following three core banking functions: Receiving deposits; paying checks; or lending money.” Supreme Court’s 1984 decision Chevron U.S.A.

Fintech 68

Fintech New York National Regulation 68

Abrigo

NOVEMBER 22, 2021

Consumer Lending Laws & Compliance Financial institutions offering consumer loans need to know about these major consumer lending laws and recent compliance issues. You might also like this webinar, "Consumer Lending 101.". Consumer lending compliance spotlight. Pandemic Issues.

Compliance 195

Compliance Lending Risk Management Regulation 195

CFPB Monitor

DECEMBER 3, 2018

On November 15, 2018, in response to a November 7, 2018 letter from Republican Senators , FDIC Chairman Jelena McWilliams announced that the FDIC has engaged outside counsel to investigate the Obama-era Operation Choke Point, under which the FDIC and other government agencies pressured banks not to do business with payday lenders.

FDIC 68

FDIC Operations Exercises Policies 68

CFPB Monitor

OCTOBER 29, 2020

24, 371 and 1464(c), respectively) that allow national banks and federal savings associations to engage in lending, by clarifying when a bank has exercised its lending authority. We continue to hope for a substantially similar “true lender” rule from the FDIC.

National 60

National Lending Exercises FDIC 60

CFPB Monitor

OCTOBER 19, 2020

Key takeaways regarding the implications of a blue wave scenario include the following: Chris Willis commented that the CFPB’s approach to the exercise of its authorities is likely to reflect criticism by Democrats that the CFPB has been lax in its approach to industry under Director Kraninger’s leadership. (In

Leadership 78

Leadership FDIC Exercises Lending 78

CFPB Monitor

FEBRUARY 19, 2021

(Similar uncertainty exists as to the OCC’s “true lender” rule and the FDIC’s Madden -fix rule which are also the subject of pending litigation. The OCC also failed to consider the Rule’s impact on facilitating predatory lending arrangements between national banks and non-banks. We will report ensuing developments.

FDIC 78

FDIC National Illinois Exercises 78