CFPB Monitor

AUGUST 25, 2020

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.

FDIC 78

FDIC District of Columbia North Carolina Illinois 78

Jeff For Banks

DECEMBER 10, 2024

The FDIC designated SVB as systemically important. They were under an FDIC consent order from 2014 through 2020 relating to their BSA and OFAC compliance and their relationship with third parties seeking access to the banking system. Its national lending program represents all but a small percentage of its entire loan portfolio.

Las Vegas 70

Las Vegas Lending Community Bank North Carolina 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

A California federal district court judge recently rejected the California AG’s challenge (in which other states joined) to the FDIC’s rule and, in a separate lawsuit, also rejected a challenge by the California AG and other state AGs to the OCC’s Madden -fix rule codified at 12 C.F.R. Section 7.4001(e).

California 78

California Innovation Utah West Virginia 78

CFPB Monitor

DECEMBER 18, 2020

The Attorneys General of California, Illinois, and New York have filed a motion for summary judgment in their lawsuit filed against the Office of the Comptroller of the Currency (OCC) to enjoin the OCC’s final rule purporting to override the Second Circuit’s Madden decision as to national banks and federal savings associations.

FDIC 78

FDIC District of Columbia North Carolina New Jersey 78

Jeff For Banks

APRIL 14, 2022

A Primer on Money, Banking, and Gold 2008 Cordelia Frances Biddle Biddle, Cordelia Frances Biddle, Jackson, and a Nation in Turmoil: The Infamous Bank War 2021 Alan S. Inside the FDIC: Thirty Years of Bank Failures, Bailouts, and Regulatory Battles 2015 Louis D. The Courage to Act: A Memoir of a Crisis and Its Aftermath 2015 Peter L.

America 60

America National Denver United States 60