#BNPL

23 05, 2022

DAILY052322

2023-02-21T13:53:43-05:00May 23rd, 2022|2- Daily Briefing|

FRB-NY Staff: Mandatory Flood Insurance Harms LMI Households

A New York Fed blog post today points to another important, unintended consequence of well-meaning regulation: the adverse impact of mandatory flood-insurance coverage on LMI households.

FRB Atlanta Staff Bolsters Proposed Cash Acceptance Mandate

blog post today from the Federal Reserve Bank of Atlanta strengthens the case for the mandate for retailer cash acceptance recently approved by the House Financial Services Committee.

Kansas City Fed Finds Persistent Commodity-Market Price Hikes, Volatility

Reflecting concerns in a recent Petrou op-ed, the Federal Reserve Bank of Kansas City today released a report differing from the FOMC’s optimistic inflation forecasts at least as far as they relate to commodities.

HFSC Tackles Disability Rights

Tomorrow’s HFSC Subcommittee on Diversity and Inclusion hearing on disability rights will focus not only on housing access, but also on the extent to which a broad range financial services are easily accessible to persons with disabilities.

Fed Survey Shows Significant LMI Investment in Payment, Investment Crypto

The Fed today released a report on household well-being in 2021, detailing an array of survey findings that generally show Americans feeling remarkably prosperous and satisfied.  The Fed cautions that this may no longer pertain, but the data do suggest what may be more than a passing rebound in economic resilience for at least some families.

Daily052322.pdf

24 01, 2022

Daily012422

2023-04-20T14:55:24-04:00January 24th, 2022|2- Daily Briefing|

FFIEC Advances Exam-Reform Initiative

Completing the final phase of its Examination-Modernization Project, the FFIEC late last week issued best practices for requesting examination information from supervised entities.  Best practices include requesting only risk-focused and relevant information, giving institutions sufficient time, and examiner coordination to avoid duplicative and/or redundant requests.

CFPB Seeks Comment on BNPL

The CFPB’s inquiry into buy-now/pay-later (BNPL) providers along with questions for public comment  were posted in today’s Register.

Daily012422.pdf

12 01, 2022

Daily011222

2023-04-24T15:42:45-04:00January 12th, 2022|2- Daily Briefing|

Ag Committees Enter Crypto Fray

Flexing their jurisdictional muscle, the bipartisan leadership of the House and Senate Agriculture Committees today sent a letter to the CFTC urging it to govern cryptoassets which, they say, are commodities.

CFPB UPs the Ante for Its Anti-BNPL Inquiry

The CFPB today broadened its market-monitoring demand of buy-now-pay-later (BNPL) providers into a general request for public comment.  Focusing in particular on consumers and international agencies, the Bureau seeks views on matters such as risks and benefits, merchant experience, and ways to improve the sector.

Daily011222.pdf

16 12, 2021

Daily121621

2023-05-22T16:01:11-04:00December 16th, 2021|2- Daily Briefing|

FHFA Constructs a GSE Stress-Capital buffer
Building on its pending rewrite of GSE-capital rules, FHFA today proposed capital-planning requirements for Fannie Mae and Freddie Mac akin in many ways to those governing large banks.   

Campaign Advances to Oust McWilliams
Ramping up the FDIC battle, Public Citizen today called on President Biden to oust FDIC Chair McWilliams.  Confirming those who have suggested that the fracas is about more than bank M&A, the letter is signed not only by many consumer-advocacy groups, but also by climate-change interest organizations.

Democrats Demand BNPL Review, CFPB Obliges
Acting quickly on Senate Democrats’ request, the CFPB today launched an inquiry into buy now, pay later (BNPL) credit, requesting information from five BNPL credit providers on BNPL risks and benefits.

FSB Says Global NBFIs are Stable, Shrinking vs. Banks
The FSB today released its annual NBFI monitoring report, concluding somewhat puzzlingly that balance-sheet NBFI vulnerability measures appeared broadly stable comparing 2020 and 2019 despite the market volatility at the pandemic’s outset and massive government intervention.

OCC Begins Climate-Risk Regulatory Build-Out
As promised, the OCC today issued draft climate risk-management principles that, when finalized, would guide future agency action starting next year.

Daily121621.pdf

15 12, 2021

Daily121521

2023-05-23T12:22:59-04:00December 15th, 2021|2- Daily Briefing|

HFSC GOP Try to Restrain FDIC Democrats
Squaring off in the partisan battle over FDIC merger policy, HFSC Republicans have launched their own investigation into what they call the Democrats’ “power grab.”  Republicans also “demanded” that Chairwoman Waters (D-CA) convene an oversight hearing even as they seek Democrats to join their inquiry.

Powell Commends MMF Proposal, Demurs on Crypto Risk
As expected, Fed Chair Powell’s press conference today focused almost entirely on inflation.  However, Mr. Powell used a question on financial stability to applaud the SEC’s MMF proposal (see alert earlier today).  Asked about crypto’s financial-stability risk, the Fed chair discounted near-term systemic risk, but consumer protection and market issues such as leverage outside the Fed’s jurisdiction warrant attention.

Senate Dems Demand BNPL Standards
Sen. Jack Reed (D-RI) was joined today by Banking Chairman Brown (D-OH), Sen. Warren (D-MA), and other Committee Democrats in calling on the CFPB to regulate buy-now, pay-later (BNPL) products.

SEC Advances Controversial Swing-Pricing MMF Rewrite
Acting on a major FSOC, Fed, and global worry, the SEC today approved a multi-prong proposal realigning MMF liquidity standards and clarifying how MMFs can handle negative rates.  The most controversial of the options would impose swing pricing on prime institutional and tax-exempt funds, an approach about which two Democratic commissioners expressed some concerns and the FSB seemed particularly skeptical in its recent MMF-options paper (see FSM Report MMF18).

Daily121521.pdf

1 11, 2021

Daily110121

2023-06-05T10:37:24-04:00November 1st, 2021|2- Daily Briefing|

FSB Presses NBFI Analysis, Bank Inter-Connectedness
The FSB today updated its late-2020 paper on nonbank financial intermediaries (see Client Report NBFI), largely reiterating the reasons it then said that global regulators need to act without indicating any actual action beyond its recent MMF Principals (see FSM Report MMF18) and work focused on margin calls.

HFSC Dems: BNPL, Other Fintech Products Present Consumer-Protection Risks
Ahead of its Fintech Task Force hearing tomorrow examining buy-now, pay-later and other fintech cash-flow products, HFSC’s majority staff memo indicates Democrats have significant consumer-protection concerns although no immediate solutions to address them.

PWG Slams Stablecoins, Agencies Outline Action Plan
The President’s Working Group today spearheaded an inter-agency report on stablecoins that, as anticipated, takes a very dim view of this form of cryptography outside the regulatory perimeter. As we will detail shortly in an in-depth analysis, the report lays out a litany of systemic, compliance, trading, and consumer concerns, noting in particular key gaps when it comes to the payment system.

Fed Study Shows Macro Impact of Fed Muni Backstop
A new FRB-NY Staff paper looks at the Fed’s municipal-debt backstop, concluding that it served not only as a generic muni-market stabilizer, but also as a credit risk-share facility for low-rated issuers that supported municipal employment at the worst of the crisis.

 

Daily110121.pdf

15 09, 2021

Daily091521

2023-08-03T14:55:22-04:00September 15th, 2021|2- Daily Briefing|

FHFA Changes Capital Course on Key Requirements
Yesterday, FHFA said it would soon issue revisions to GSE capital regulation. Today, it did, proposing to retract the prior rule’s dim view of credit-risk transfer (CRT) with a new approach actively promoting it.

Acting Comptroller Expands on Equality Banking, Other Priorities
In remarks today, Acting Comptroller Hsu reiterated his priorities: reducing inequality, addressing digitalization, countering climate risk, and guarding against complacency.

Daily091521.pdf

8 09, 2021

FedFin on: Small-Business Lending Disclosures

2023-08-21T13:45:34-04:00September 8th, 2021|The Vault|

Turning again to a provision in the 2010 Dodd-Frank Act, the Bureau of Consumer Financial Protection has issued a sweeping proposal to implement small-business and small-farm lending disclosure requirements akin to those long required under the Home Mortgage Disclosure Act (HMDA).  Although the law focuses on lender reports to discern different loan-approval rates based on gender or ethnic/racial groups, the notice of proposed rulemaking (NPR) goes farther also to require extensive detail on loan amounts and pricing on approved loans a borrower chooses not to accept.  Data would be required from all but the very smallest bank and nonbank lenders.

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

8 09, 2021

SBA40

2023-08-21T13:45:46-04:00September 8th, 2021|1- Financial Services Management|

Small-Business Lending Disclosures

Turning again to a provision in the 2010 Dodd-Frank Act, the Bureau of Consumer Financial Protection has issued a sweeping proposal to implement small-business and small-farm lending disclosure requirements akin to those long required under the Home Mortgage Disclosure Act (HMDA).  Although the law focuses on lender reports to discern different loan-approval rates based on gender or ethnic/racial groups, the notice of proposed rulemaking (NPR) goes farther also to require extensive detail on loan amounts and pricing on approved loans a borrower chooses not to accept.  Data would be required from all but the very smallest bank and nonbank lenders.

SBA40.pdf

8 09, 2021

SMBUS27

2023-08-21T13:53:42-04:00September 8th, 2021|1- Financial Services Management|

Small-Business Lending Disclosures
Turning again to a provision in the 2010 Dodd-Frank Act, the Bureau of Consumer Financial Protection has issued a sweeping proposal to implement small-business and small-farm lending disclosure requirements akin to those long required under the Home Mortgage Disclosure Act (HMDA). Although the law focuses on lender reports to discern different loan-approval rates based on gender or ethnic/racial groups, the notice of proposed rulemaking (NPR) goes farther also to require extensive detail on loan amounts and pricing on approved loans a borrower chooses not to accept. Data would be required from all but the very smallest bank and nonbank lenders.

SMBUS27.pdf

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