On July 25, 2024, the Board of Governors of the Federal Reserve System (FRB), Federal Deposit Insurance Corporation (FDIC) and Office of the Comptroller of the Currency (OCC) issued a joint statement describing potential risks related to banks’ deposit arrangements with fintechs and other third parties. The agencies also published…
Articles Posted in Finance
CFPB Proposed Rule Puts Non-Bank Consumer Contract Clauses Under Heightened Scrutiny
The Consumer Financial Protection Bureau (CFPB), the primary federal regulator charged with enforcing consumer financial protection laws, recently announced a proposed rulemaking that would require the myriad non-banks subject to CFPB authority to disclose various consumer contract provisions that the CFPB deems potentially harmful on a public registry. These provisions…
UK Financial Regulators to Oversee Critical Third Parties
In UK Financial Regulators to Oversee Critical Third Parties, our colleagues Lee Rubin and Mark Booth discuss the proposed new regime that will grant UK federal regulators a range of powers over third parties that provide critical services to the financial sector.
U.S. Financial Regulators Propose Rule that Supervisory Guidance Does Not Equal Law
On October 20, 2020, a consortium of U.S. federal financial regulators (Regulators)[1], issued a proposed rule (Proposed Rule) that, if enacted, would codify that mere supervisory guidance that is not the product of notice and comment rulemaking—e.g., interagency statements, advisories, bulletins, policy statements, and FAQs—does not have the force of law.…
European Banking Authority Outsourcing Guidelines: Time to Act
From September 30, 2019, new guidelines on outsourcing arrangements (Guidelines) issued by the European Banking Authority (EBA) will apply to all outsourcing arrangements entered into, reviewed or amended on or after this date. The Guidelines aim to establish a more harmonized framework for all financial institutions that are within the…