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4 11, 2022

FedFin: Consumer Data Rights

2022-11-04T15:47:45-04:00November 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.…

4 11, 2022

DATA3

2022-11-04T10:36:30-04:00November 4th, 2022|1- Financial Services Management|

Consumer Data Rights

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 and the rights and remedies they have following a decision to open their personal data to parties other than the entity that holds key accounts.

DATA3.pdf

21 10, 2022

FedFin on: DSIB-Resolution Requirements

2022-10-21T15:51:53-04:00October 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.…

21 10, 2022

RESOLVE48

2022-10-21T14:12:50-04:00October 21st, 2022|1- Financial Services Management|

DSIB-Resolution Requirements

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 agencies decide to include them in total loss-absorbency capacity (TLAC) standard for covered banking organizations akin to those now governing GSIBs.

RESOLVE48.pdf

19 10, 2022

DEPOSITINSURANCE115

2022-10-24T11:19:32-04:00October 19th, 2022|5- Client Report|

FDIC Hikes Premiums, Presses Resolvability

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 to advance his campaign against big banks and mergers, calling for an overall review of FDIC premiums to charge the largest banks more and an end to “lax” merger approvals.  This report summarizes today’s meeting; in-depth reports on the final rule and ANPR will follow.

DEPOSITINSURANCE115.pdf

18 10, 2022

FedFin on: FDIC Hikes Premiums, Presses Resolvability

2022-10-24T11:21:49-04:00October 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.…

14 10, 2022

AL101722

2022-10-14T17:07:31-04:00October 14th, 2022|3- This Week|

Ouch?

Later this week, the FDIC board will decide whether to hike DIF premiums as proposed earlier this year (see FSM Report DEPOSITINSURANCE114).  The banking industry is arrayed against this not only because it’s costly, but also – as our analysis addressed – procyclical.  We will provide clients with an in-depth analysis of the final rule along with the meeting, which now also includes a certain vote in favor of FDIC agreement to the ANPR released late last week by the Fed asking an array of questions on large-bank resolvability.  We will also provide clients with an in-depth analysis of this ANPR along with the accompanying orders setting new merger policy by way of the Fed and OCC decisions on the USB/MSFG transaction.  These actions make it clear that mergers will be approved even in the absence of the formal Fed policy promised by Vice Chairman Barr, but the terms and conditions will be considerably stricter than was the case just a year ago for other super-regional transactions.

Al101722.pdf

14 10, 2022

DAILY101422

2022-10-14T17:04:18-04:00October 14th, 2022|2- Daily Briefing|

Along with a Squeaker Merger Approval, Fed/FDIC Begin Work on Large-Bank Resolvability

As anticipated in Karen Petrou’s speech yesterday, the Fed today unanimously approved and the FDIC will shortly do the same on an advance notice of proposed rulemaking re-enforcing large-bank resolvability.  That this complex rulemaking will not slow near-term merger decisions was made clear today also by the Fed and OCC decisions to clear USB’s acquisition of MSFG’s California banking organization.

Covid Comm Presses CFPB for Still More Credit-Reporting Reform

The Chairman of the Select Subcommittee on the Coronavirus Crisis, Rep. James Clyburn (D-NC) sent a letter to CFPB Director Chopra requesting that the Bureau investigate the three nationwide consumer reporting agencies (NCRAs) for failing to properly address credit reporting errors.  Citing data, the Subcommittee obtained from the NCRAs, Chairman Clyburn alleges that reporting errors occurred far more often than previously thought, that the majority of disputes do not result in consumer relief, and that the NCRAs discarded “tens of millions” of submissions without investigation by claiming they came from unauthorized third-parties.

Waller Dismisses Threat To Reserve Dollar Without A CBDC

In remarks today, FRB Governor Waller reiterated his skepticism of foreign-issued CBDCs and stablecoins, arguing that the underlying reasons for dollar dominance are non-technological and CBDCs will not affect them.  He dismisses concerns that foreign CBDCs would undermine dollar dominance because they could neither reduce payment frictions nor prevent illicit finance.

Daily101422.pdf

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