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

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

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

American Banker

JULY 2, 2024

Maryland-based Forbright Bank, which is led by a onetime Democratic presidential candidate, relied extensively on brokered deposits as it grew after a 2021 rebranding. The bank says it has made changes in response to regulators' concerns.

Maryland 45

Maryland FDIC Regulation Compliance 45

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