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15 03, 2024

Al031824

2024-03-15T17:23:21-04:00March 15th, 2024|3- This Week|

Answered Prayers?

Banks have been asking regulators for years – decades? – to update 1995 merger guidance.  So the banking agencies are beginning to do, but not exactly as banks would have liked to see it done.  Although Sen. Warren (D-MA) thinks the OCC’s proposed merger policy is too soft, our analysis (see FSM Report MERGER14) and that of many others finds it a formidable barrier to all but the simplest, smallest transactions.  Now comes the FDIC.  As the schedule below makes clear, it plans on Thursday to issue a proposal based on its 2021 RFI (see FSM Report MERGER9).  We doubt any bank-merger policy influenced as strongly by CFPB Director Chopra will be a bank merger policy banks will like any better than the OCC’s, although some compromises may have to be made if Republican members of the FDIC board are willing to contemplate at least some of what Mr. Chopra, surely seconded by Chair Gruenberg, wants done.

Al031824.pdf

15 03, 2024

Daily031524

2024-03-15T17:22:26-04:00March 15th, 2024|2- Daily Briefing|

Effective Date for Late-Fee Ban Set for May

Publication in the Federal Register today sets the effective date for the CFPB credit-card late fee regulation (see FSM Report CREDITCARD37) as May 14, 2024.  The rule sets a controversial $8 safe harbor for late fees by larger issuers and mandates a stringent fee-calculation methodology for smaller issuers.  The Bureau did, however, forbear setting limits on other card fees such as those associated with over-limit purchases.  Litigation contesting the rule is already in the works along with a GOP resolution to overturn it.

Vance Goes for Nuclear Financial-Market Option vs. China

Sen. Vance (R-OH) has introduced S. 3945, a bill to ban China and entities it governs from U.S. capital, bond, and financial markets if Treasury determines that it has engaged in sovereign-debt restructuring in violation of global law and financial-market practice.  The goal here is clearly to force China to cease the practice of throwing emerging-market debtors into default on debt it has extended while securing repayment or other beneficial treatment for itself.

Daily031524.pdf

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