#rfi – Federal Financial Analytics

12 06, 2024

FedFin on: AI Implementation

Arezou Rafikian2024-06-12T14:46:06-04:00June 12th, 2024|The Vault|

Although pressed by Congress to reach conclusions about AI’s risk in the financial sectors, Treasury is following up the worries in the most recent FSOC report with only a request for information (RFI) from the public. The RFI follows an Executive Order (EO) from President Biden in 2023 instituting a “whole-of-government” program to identify best-use and high-problem aspects of AI from both a private- and -public sector perspective….

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5 06, 2024

FedFin on: Closing In on Closing Costs

Arezou Rafikian2024-06-05T11:21:39-04:00June 5th, 2024|The Vault|

As anticipated, the CFPB has advanced its campaign to quell mortgage closing costs. But, unlike our forecast, the usually-aggressive agency is sliding into this debate with only a request for information (RFI) asking lots of questions we though the CFPB had already answered to its own satisfaction given a prior study and much ancillary “junk fee” commentary from Director Chopra and even the White House NEC Director.

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

1 02, 2022

FedFin: “Fair-Fee” Policy

Arezou Rafikian2023-04-05T14:22:57-04:00February 1st, 2022|The Vault|

Taking action to advance President Biden’s competition order, 1 the CFPB is seeking views on fees which it believes exploit consumers by virtue of unfair competition. Although many of the fees it cites are covered by statutory
disclosure regimes designed to ensure both front- and back-end fee transparency, the Bureau believes that many of these fees are unfair due to large-bank market power.

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

6 01, 2022

Analysis of AML/CFT Regulatory Reform

Arezou Rafikian2023-04-25T15:45:12-04:00January 6th, 2022|The Vault|

As the banking industry has long hoped and Congress last year directed,1 FinCEN is beginning to develop a new policy framework prioritizing ways to make anti-money laundering (AML) and countering the financing of terrorism (CFT) regulation more risk-based. FinCEN is taking the opportunity of its request for information (RFI) also to seek views on ways to modernize AML/CFT standards, make them more efficient, ensure adherence to global protocols, and toughen rules where necessary to protect national security. Last year’s law required Treasury to enhance law enforcement and submit a report on AML/CFT….

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16 12, 2021

FedFin: Bank Merger Policy

Arezou Rafikian2023-05-22T16:11:59-04:00December 16th, 2021|The Vault|

Released in a highly-controversial fashion (see below) by two Democrats on the FDIC’s board, this RFI posits the need for a significant review of mergers involving insured depository institutions (IDIs) due to many changes in the financial industry and, so it says, the lack of substantive competitive analysis over past decades even of the largest transactions.

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18 11, 2021

FedFin Analysis of: HMDA Rewrite

Arezou Rafikian2023-05-26T10:31:04-04:00November 18th, 2021|The Vault|

The CFPB has followed a study earlier this year finding significant mortgage product and price discrepancies based on race or ethnicity with a request for input (RFI) on the HMDA data on which the study was based. This is a preliminary effort with no immediate regulatory or supervisory consequences, but it likely presages a significant HMDA-regulatory rewrite in no later than 2023 to provide still more firepower for ongoing CFPB, Department of Justice, and bank-regulatory actions against credit discrimination and redlining.

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