CFPB Monitor

MAY 6, 2021

A Maryland administrative action recently removed to the state’s federal district court illustrates how Maryland law continues to present challenges for the bank partner structure used by many lenders. The new Maryland matter demonstrates that participants in bank model programs continue to face state licensing threats.

Maryland 78

Maryland Lending Missouri FDIC 78

CFPB Monitor

SEPTEMBER 10, 2020

Because CCBank is a state-chartered FDIC-insured bank located in Utah, Section 27(a) of the Federal Deposit Insurance Act authorizes CCBank to charge interest on its loans, including loans to California residents, at a rate allowed by Utah law regardless of any California law imposing a lower interest rate limit.

Utah 78

Utah California FDIC West Virginia 78

Jeff For Banks

JUNE 2, 2023

The old borrow short, lend long strategy. I want to read to you the FDIC’s conclusion from their An Examination of the Banking Crisis of the 1980’s and Early 1990’s. Who would’ve thought lending $1 million to a San Francisco cab driver to buy a house at 100% loan to value would go bad? We took a serious reputational hit.

FDIC 78

FDIC Community Bank Regulation Lending 78

Independent Banker

APRIL 30, 2022

In order to compete as a small bank, we have been forced to keep higher-than-peer capital levels, so that our lending limit allows us to service local borrowers’ needs. based bank attributes its growth to a hot housing market, its focus on builder and home mortgage lending, and the economic success in its markets. “We

Community Bank 172

Community Bank Community Montana Taxes 172

PYMNTS

JANUARY 30, 2018

Maryland Representative Elijah Cummings and California’s Representative Jimmy Gomez, in an open letter to BoA CEO Brian Moynihan, said that many low-income American families rely on the account. Customers can also keep a daily balance of $1,500 to avoid fees. Those who do not meet those criteria will pay a $12 monthly fee.

America 109

America Maryland FDIC Millennials 109

CFPB Monitor

NOVEMBER 1, 2021

With help from Ballard Spahr colleagues Mindy Harris and Ron Vaske, I have now completed a months-long project in updating and expanding a 2017 White Paper addressing bank-model lending—programs involving partnerships between banks (or savings associations) and fintech or other nonbank companies in the interstate delivery of loans.

Lending 78

Lending Maryland FDIC Analysis 78

CFPB Monitor

JUNE 15, 2022

Four Democratic members of the California state legislature recently sent a letter to the Federal Deposit Insurance Corporation (FDIC) urging the agency to take action against FDIC-supervised banks that partner with non-bank lenders to originate high-cost installment loans.

FDIC 78

FDIC California West Virginia North Carolina 78