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

Jeff For Banks

FEBRUARY 6, 2011

The FDIC has nearly quadrupled its enforcement actions (“EA”) over the past three years. The productive view about the similarity of EAs is why haven’t we been doing some of the things required by regulators in the first place? Banking is a highly regulated industry, and has been since the Great Depression.

Regulation 70

Regulation FDIC National Capital 70

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

CFPB Monitor

MARCH 15, 2022

The OCC’s attempt to provide a clear bright line test for determining when a bank is the “true lender” in a bank-model program through a regulation was overturned by Congress under the Congressional Review Act.) Maryland, New York, North Carolina, Ohio, Pennsylvania, West Virginia, and Colorado.

California 78

California Innovation Utah West Virginia 78

Jeff For Banks

JUNE 2, 2023

Second, this can be accomplished only if the industry does not have too much influence over its regulators and if the regulators have the ability to hire, train, and retain qualified staff. Third, the regulators need adequate financial resources. My lesson learned to the regulators, read your past lessons learned.

FDIC 60

FDIC Community Bank Regulation Lending 60

Independent Banker

DECEMBER 13, 2015

These agencies had input: the Federal Reserve, the Office of the Comptroller of the Currency, FDIC and the National Credit Union Administration. No one knows yet how in-depth the regulators might want those assessments.”. Ellen Ryan is a freelance writer in Maryland.

Tools 70

Tools Community Community Bank Security 70

Independent Banker

NOVEMBER 24, 2015

These agencies had input: the Federal Reserve, the Office of the Comptroller of the Currency, FDIC and the National Credit Union Administration. No one knows yet how in-depth the regulators might want those assessments.”. Ellen Ryan is a freelance writer in Maryland.

Tools 70

Tools Community Community Bank Security 70