Financial Institutions
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FFIEC Announces Final Update for Examination Modernization Project
On January 21, 2022, the Federal Financial Institutions Examination Council ("FFIEC") issued a final statement presenting the results of the Examination Modernization Project reaching its final phase.
CFPB Issued a Request for Public Comment on “Buy Now, Pay Later”
On January 12, 2022, the CFPB issued a request for public comment on their inquiry into BNPL and general opinion of BNPL providers.
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.
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.”
OCC Renews Climate Risk Management Survey for Large Banks
On January 18, 2022, the Office of the Comptroller of the Currency (“OCC”) announced the renewal of the survey it created addressing climate risk management practices at larger OCC-regulated banks.
Federal Reserve Chair Signals Climate Stress Tests Are Likely to be Implemented
On January 10, 2022, Federal Reserve Chair Jerome Powell addressed the likelihood of the implementation of climate stress tests at his confirmation hearing before the Senate Banking Committee.
OCC Comptroller Argues in Favor of Bank Regulation to Slow Cryptocurrency Risk
On January 13, 2022, Acting Comptroller Michael J. Hsu of the Office of the Comptroller of the Currency (“OCC”) made remarks before the British American Business Transatlantic Finance Forum Executive Roundtable regarding the future of crypto-assets and regulation.
Federal Agencies Act to Advance Diversity and Inclusion
On January 21, 2022, Federal Deposit Insurance Corporation (“FDIC”) Chairman Jelena McWilliams issued remarks on diversity and inclusion at the FDIC and National Bankers Association Event.
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.
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.
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.
CFPB Releases Rural and Underserved Counties List
In 2022, the Consumer Financial Protection Bureau (CFPB) released its annual rural and underserved counties list during the 2021 period for lenders to review and utilize.
Canadian Prime Minister Announces Mandatory Climate-Related Financial Disclosures Plan
On December 16, 2021, Canadian Prime Minister Justin Trudeau announced that Canada was establishing a plan to compel Canadian companies to comply with mandatory climate-related financial disclosures.
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).
Federal Reserve Board Adds FAQs to Regulation’s Legal Interpretations
On December 30, 2021, the Federal Reserve Board (FRB) published updated frequently asked questions (FAQs) to several regulations including existing legal interpretations to “increase transparency and enhance accessibility.”
CFPB Updates Whistleblower Website and Calls for Tech Workers to Act
On December 15, 2021, the Consumer Finance Protection Bureau (CFPB) announced that it had redesigned its whistleblower webpage to enhance tech worker’s reporting experience.
OCC Taking Action on Climate Risk Management Principals for Large Banks
On December 16, 2021, the Office of the Comptroller of the Currency (OCC) issued draft principals on how OCC-supervised large banksthose with more than $100 billion in total consolidated assetsmust identify and manage climate-related financial risks.
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.
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.”
DOJ Antitrust Division Seeks Additional Comment on Bank Merger Guidelines
On December 17, 2021, the U.S. Department of Justice (DOJ) announced that it was seeking additional public comments on potential revisions to the Bank Merger Competitive Review Guidelines (Banking Guidelines) that were enacted in 1995.