#ANPR

4 11, 2022

FedFin: Consumer Data Rights

Arezou Rafikian2022-11-04T15:47:45-04:00November 4th, 2022|The Vault|

Beginning a long-awaited rulemaking process on the extent to which consumers have rights to their own data and how these rights may be exercised, the CFPB is seeking views on an array of ideas and questions to guide future action. This outline is essentially an advance notice of proposed rulemaking (ANPR) in which the Bureau outlines its initial thinking on key questions such as the extent to which screen-scraping should be allowed, whether new security standards are needed, and when consumers are at risk…

The full report is available to retainer clients. To find out how you can sign up for the service, click here and here.…

FedFin on: DSIB-Resolution Requirements

Arezou Rafikian2022-10-21T15:51:53-04:00October 21st, 2022|The Vault|

The FRB and FDIC have moved beyond the resolution-planning requirements mandated in the Dodd-Frank Act then implemented over the years to what could be a new resolution regime for banking organizations considered category II or III companies under the inter-agency tailoring rules. Initially described as guidance when the agencies first announced this initiative, it appears likely that final standards will be more binding, which would almost certainly need to be the case under administrative procedures if the agencies decide not only to revise resolution planning on a sector or bank-by-bank case. This would be particularly likely if ….

The full report is available to retainer clients. To find out how you can sign up for the service, click here and here.…

FedFin on: FDIC Hikes Premiums, Presses Resolvability

Arezou Rafikian2022-10-24T11:21:49-04:00October 18th, 2022|The Vault|

The FDIC board today voted 3-0 to increase DIF assessment rates by 2bps, finalizing its proposal (see FSM Report DEPOSITINSURANCE114) and rejecting industry arguments on grounds that a small DIF premium increase now would make a more damaging procyclical assessment increase under adverse economic conditions less likely. Unsurprisingly, the FDIC also joined the Fed in approving the ANPR that bears its name, with Acting Comptroller Hsu praising the ANPR’s balance between protecting financial stability and competition among the largest banks. CFPB Director Chopra used his remarks…

The full report is available to retainer clients. To find out how you can sign up for the service, click here and here.…