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OCC and FDIC issue joint proposal to revise CRA regulations; Ballard Spahr to hold Jan. 29 webinar

CFPB Monitor

The OCC and FDIC have issued a joint proposal to revise their regulations implementing the Community Reinvestment Act (CRA). Although the Federal Reserve, OCC and FDIC, are the primary CRA regulators, the Fed did not join the proposal and presumably will issue a separate proposal. On January 29, 2020, from 12 p.m. Our thoughts.

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FDIC issues “Madden fix” rule addressing state bank loan interest rates after assignment

CFPB Monitor

The FDIC has issued its widely anticipated final rule resolving the uncertainty caused by the Second Circuit’s Madden v. The FDIC’s Notice of Proposed Rulemaking (“NPR”) was published the same week as an OCC proposed rule intended to address the same issue for national banks under Section 85. Midland Funding decision.

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This week’s podcast episode: What recent developments in federal preemption for national and state banks mean for bank and nonbank consumer financial services providers

CFPB Monitor

In this episode, which repurposes a recent webinar, we first discuss the U.S. Providers of consumer financial services that rely on federal preemption to charge customers uniform interest rates and fees on a nationwide basis are currently facing a series of legislative and litigation challenges. Continue Reading

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Colorado state court rules federal interest rate preemption for state bank loans does not extend to non-bank assignees; Ballard Spahr to hold June 19 webinar

CFPB Monitor

Section 27, which applies to state banks, is patterned after Section 85 of the National Bank Act, which applies to national banks. In Madden , the Second Circuit ruled that a purchaser of charged-off debts from a national bank was not entitled to the benefits of the preemption of state usury laws under Section 85. to 1:00 p.m.

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The Current Banking Crisis – 10 Not So Apparent Lessons

South State Correspondent

Percentage of Uninsured Deposits: At the time of failure, SVB had approximately 88% of their deposits above the FDIC-insured $250k limit and ran at 95% at the end of last year. Some form of this ratio will likely be applied to the national and regional banks, which means larger community banks will also be judged by this ratio.

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The Future of Noninterest Income at Financial Institutions

Abrigo

You might also like this webinar: "Is inflation the big gift to your 2022 earnings?". To remain competitive, some of the nations’ largest banks have introduced new products. Noninterest income drove 20% of community banks' net operating revenue in 2019, down from 22% in 2012, according to a recent FDIC study.

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California Dept. of Business Oversight launches “true lender” investigation of auto title lender’s partnership with Utah bank

CFPB Monitor

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. to 4:30 p.m.

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