19 08, 2022


2023-01-04T11:09:21-05:00August 19th, 2022|3- This Week|

A Payment System Premised on Peccadillos? 

As we noted at the start of this month, August may seem quiet, but that’s only because Congress is more or less muffled.  Regulators remain busy, with the CFPB a-churn with new actions.  Our in-depth analyses of the Bureau’s new digital-marketing rule (see FSM Report FINTECH30) and data-safeguards standards (see FSM Report INFOSEC28) make clear that the CFPB never sleeps.  Bank regulators are also wakeful, with the most recent evidence of this to be found in the FDIC’s NSF-fee clamp down and the Fed’s supervisory cryptoasset statement and striking new payment-system access policy (see FSM Report PAYMENT25).  As our in-depth analysis describes, this policy could well redefine winners and losers across the entire spectrum of U.S. financial services.


18 08, 2022


2023-01-04T11:25:52-05:00August 18th, 2022|2- Daily Briefing|

CFPB Plans to Change Credit-Card Filings

The CFPB is seeking comments on revisions to reports it receives on credit-card terms and those related to certain cobranding agreements.  Although the new data are not described, the Bureau is likely planning to gather more information supporting its campaign to limit “junk fees, (see FSM Report CONSUMER38), govern credit-card late fees (see FSM Report CREDITCARD35), and otherwise restructure this sector.

IMF Blog: Climate Finance Should Blend Public/Private Sectors

An IMF blog post today by its managing director Kristalina Georgieva and Tobias Adrian advocates for blending public and private sector finance as a way of de-risking climate finance.  Advocating options that pose challenges under both U.S. law and longstanding-policy tradition, the Fund recommends public-sector equity investments and credit enhancements, highlighting additional financing practices it says would reduce impediments to private capital such as public-private partnerships, multi-sovereign guarantees, and separate underwriting for risks such as political instability.

FDIC Takes Concrete Anti-Overdraft Action

Although the CFPB has blasted overdraft fees and Acting Comptroller Hsu has suggested that they may pose supervisory concerns, the FDIC today took concrete action against them.  In a new supervisory edict, it announced that state nonmember banks receiving multiple NSF fees for the same transaction risks supervisory sanction because such fees are unsafe and unsound.


20 07, 2022


2023-01-06T14:31:13-05:00July 20th, 2022|2- Daily Briefing|

Fed Study: Mortgage Churning for CRA Adversely Affects LMI Mortgage Market

A new Fed staff paper revisits one of the longstanding questions with CRA regulation: whether allowing equal CRA credit for mortgage originations and purchases increases LMI-focused mortgage finance.  Critics of past CRA rules have argued that mortgage purchases are “churning” – i.e., the same loans are bought and sold across the marketplace at the time of each bank’s CRA examination.

Comment Deadline Extended for CFPB Relationship Banking RFI

The Federal Register today provides a 30-day comment period extension for the CFPB’s Relationship Banking RFI (see FSM Report CONSUMER43).  Comments are now due August 22.  As noted, the Bureau has inferred that preserving relationship banking requires “human touch” rapid responses to consumer inquiries that will ensure high-quality banking services are available in all markets.

CFPB Blog: Overdraft/NSF Policy Changes Reduced Fees

Expanding on its December 2021 report, a CFPB blog post today concluded that overdraft and NSF policy changes led to significant reductions in the amount bank customers incur from various account fees.  The post provides two tables — one displaying overdraft/NSF revenue and the other showing ATM fees — across multiple years and specific quarters for small and midsize banks and for select large banks.


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