Financial Institutions

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Haley Metteauer Haley Metteauer

GAO Recommends Federal Regulators Act to Increase Protection of PII

On January 13, 2022, the U.S. Government Accountability Office (“GAO”) released a report outlining their recommendations for five federal regulators on how the regulators can better protect the personally identifiable information that they collect and maintain from consumers.

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Haley Metteauer Haley Metteauer

Large Banks Establish Climate Risk Consortium

17 of the largest North American-based financial institutions joined together this month to establish the Risk Management Association’s (“RMA”) Climate Risk Consortium (“Consortium”) for “advancing awareness of and addressing risks relevant to climate change.”

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Haley Metteauer Haley Metteauer

Federal Reserve Issues Updated Main Street FAQs on LIBOR Transition

As a result of the transition away from the usage of LIBOR, all MSLP loans will have to transition away from LIBOR by June 30, 2023. To facilitate this transition, the Fed recently issued updated FAQs explaining to MSLP lenders how to transition their MSLP loans away from LIBOR.

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Haley Metteauer Haley Metteauer

CFPB Issues Final Rule Facilitate LIBOR Transition

On December 7, 2021 ,the Consumer Financial Protection Bureau ("CFPB") issued a final rule amending portions of Regulation Z, the regulation which implements the Truth in Lending Act ("TILA"), in anticipation of the sunset of LIBOR.

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Haley Metteauer Haley Metteauer

Federal Agencies Adjust Civil Penalties Due to Inflation

On January 11, 2022, the Consumer Finance Protection Bureau (CFPB), Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), and Office of the Comptroller of the Currency (OCC) released a notice making inflation adjustments to the maximum civil money penalties, effective January 15, 2022.

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Haley Metteauer Haley Metteauer

OCC Releases Annual CRA Asset-Size Threshold Adjustments

On December 30, 2021, the Office of the Comptroller of the Currency (OCC) announced a revision to the asset-size threshold amounts used to define “small bank or savings association” and “intermediate small bank or savings association” under the Community Reinvestment Act (CRA).

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Haley Metteauer Haley Metteauer

Federal Agencies Announce CBLR Framework Changes

On December 21, 2021, the Federal Reserve Board, the Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC), (collectively, the “federal agencies”) issued an interagency statement regarding changes to the optional community bank leverage ratio (CBLR) framework.

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Haley Metteauer Haley Metteauer

CFPB Inquires Into “Buy Now, Pay Later” Financing

On December 16, 2021, the Consumer Financial Protection Bureau (CFPB) announced that it ordered five companies offering “buy now, pay later” (BNPL) credit to turn over “information on the risks and benefits of these fast-growing loans.”

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