#rfi

22 03, 2023

DAILY032223

2023-03-22T17:37:57-04:00March 22nd, 2023|2- Daily Briefing|

FTC Builds On Treasury Cloud Concerns, Seeks Competition, AI Views

Signaling apprehension about a number of risks outlined in a recent Treasury report, the FTC today requested comment on the business practices of cloud computing providers.

Scott, Warren Reach Over Partisan, Ideological Divide to Blast the Fed

Demonstrating the confluence of populist and progressive thinking about the Fed we anticipated at the start of this year, Sens. Rick Scott (R-FL) and Warren (D-MA) have introduced legislation mandating that the Fed’s inspector general be fully independent of the chair and board of governors.

Fed Under Still More Pressure to Boost Regional-Bank Supervision

Sen. Warren (D-MA) continued her prolific letter-writing campaign, today also joining with Sens. Duckworth (D-IL), Blumenthal (D-CT), Sanders (I-VT), Reed (D-RI), Hirono (D-HI), Markey (D-MA), King (I-ME), Whitehouse (D-RI), Smith (D-MN), Van Hollen (D-MD), and Schatz (D-HI) to call upon Vice Chairman Barr quickly to heighten regulatory standards for banking organizations between $100 and $250 billion.

Powell Protests Suggestions Of Fed Supervisory Error

At his press conference today, Chairman Powell sought to defend the Fed so vigorously that some of his comments may ignite still more criticism.

Yellen Denies FDIC-Coverage Rewrite, Suggests Need for Liquidity-Rule Revisions

In her appearance today before the Senate Appropriations Subcommittee on Financial Services and General Government, Treasury Secretary Yellen refuted press reports that Treasury is considering significant deposit-insurance coverage expansion, saying only that the banking system is safe and it is too soon to consider structural reforms.

Daily032223.pdf

28 03, 2022

DAILY032822

2023-03-27T15:53:58-04:00March 28th, 2022|2- Daily Briefing|

Hsu Open to New Merger Policy on Inter-Agency Basis

As noted on Friday, the FDIC has now officially released a controversial RFI on bank-merger policy (see FSM Report MERGER9).  Press included a statement from Acting Comptroller Hsu indicating that he supports this public-comment effort, especially with regard to reconsidering financial stability at larger banks.

Progressives Propose a Treasury, not Central Bank, Digital Dollar

As anticipated when we reviewed a Brookings proposal for a “Treasury dollar“, legislation (H. R. 7231) has now been introduced to create what its sponsors call “ECASH” – that is, a digital currency issued by the U.S. Treasury, not the Federal Reserve.  Introduced by Rep. Stephen Lynch (D-MA) and several progressives, the ECASH program would launch three Treasury pilots under a new high-level Treasury office to create a digital dollar with physical cash’s privacy and anonymity.

House Panel Presses CS on Sanctions Compliance

Signaling a new source of sanctions-related reputational risk, the House Oversight Committee today demanded information from Credit Suisse following assertions that the bank had ordered counterparties to destroy Russia-related documentation.

Chopra Goes after Charters, Activities, Officers for Repeat Enforcement Violations

CFPB Director Chopra today expanded his attack on large financial-services firms, arguing that those who repeatedly violate consumer-protection or other core standards should lose their charters.

Daily032822.pdf

25 03, 2022

Daily032522

2023-03-27T16:04:54-04:00March 25th, 2022|2- Daily Briefing|

Fed Puts Off Finalizing New DIHC Framework
The FRB today extended the comment deadline on a longstanding proposal crafting a new regulatory framework for depository institution holding companies principally engaged in insurance services.

CFPB Wants to Hear More re Pricing Practices
Saying it has been swamped with consumer tales about “junk fees,” the CFPB today extended the comment deadline until April 11 on its request for views on this hot topic.

Bipartisan Crypto Construct Harder to Build than Describe
On a Politico webcast last night, Sens. Kirsten Gillibrand (D-NY) and Cynthia Lummis (R-WY) announced a bipartisan alliance to craft cryptoasset standards they expect to see on the Senate floor by year-end.

Waller Still Wants Little to Do with a CBDC
At a feisty panel today, FRB Gov. Chris Waller stood by his view that a CBDC is “a solution in search of a problem.”

Senate Democrats Demand Overdraft-Fee Fix
Sen. Rev. Warnock (D-GA) and Chairman Brown (D-OH) joined other Democrats demanding lower or eliminated overdraft fees.

FDIC Starts Process of Revising Bank-Merger Policy

The FDIC today has officially released the bank-merger RFI that now-Acting Chairman Gruenberg and CFPB Director Chopra sought to release under Chair Jelena McWilliams.

Daily032522.pdf

2 02, 2022

DAILY020222

2023-04-05T14:10:54-04:00February 2nd, 2022|2- Daily Briefing|

BIS Outlines Regulatory Goals for More Tech-Based Lending
A new BIS paper approaches fintech’s financial-inclusion impact from a new angle: the extent to which personal-information collateral backing consumer debt can be governed to ensure that innovation also advances inclusion without leading to undue market power and/or disintermediation.

BIS Chief Calls for CBDC ASAP
The BIS today released a speech late last month from Managing Director Carstens saying that the “soul of money” – i.e., its essence and purpose – is best entrusted to central banks, not DLT or private issuers.

CFPB Redoubles Effort Against “Junk” Fees
The CFPB today posted a note standing firmly behind its RFI seeking input on the “junk” fees the agency believes pervade consumer finance (see FSM Report CONSUMER38).

Senate GOP Heighten Objections to FDIC Democrats
Senate Republicans today strengthened their objections to the December effort by FDIC Democrats to release a bank-merger RFI (see FSM Report MERGER9), introducing legislation to strip the Board of the Comptroller of the Currency and CFPB director.

Daily020222.pdf

1 02, 2022

CONSUMER38

2023-04-05T14:14:55-04:00February 1st, 2022|1- Financial Services Management|

“Fair-Fee” Policy

Taking action to advance President Biden’s competition order, 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.  Unfairness is in part judged by the extent to which a fee exceeds the provider’s marginal cost with some recognition of possible risk, but how much of a profit margin above these break-even thresholds is neither specified nor discussed.

CONSUMER38.pdf

1 02, 2022

GSE-020122

2023-04-05T14:20:22-04:00February 1st, 2022|4- GSE Activity Report|

CFPB Goes for the Jugular

Nothing could do as much damage to a business based on fee revenue as a determined CFPB inquiry into fee revenue. Last Thursday, the Bureau’s new director, Rohit Chopra, launched just such an inquiry. Here, we assess its important to mortgage origination and servicing along with what’s next.

GSE-020122.pdf

1 02, 2022

FedFin: “Fair-Fee” Policy

2023-04-05T14:22:57-04:00February 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

AML135

2023-04-25T15:44:59-04:00January 6th, 2022|1- Financial Services Management|

AML/CFT Regulatory Reform

As the banking industry has long hoped and Congress last year directed, 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 reform by January of 2022.

AML135.pdf

6 01, 2022

Analysis of AML/CFT Regulatory Reform

2023-04-25T15:45:12-04:00January 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….

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

22 12, 2021

Daily122221

2023-05-22T13:38:02-04:00December 22nd, 2021|2- Daily Briefing|

Waters Demands McWilliams Justify RFI Blockade
As promised last week, HFSC Chairwoman Waters (D-CA) today formally requested that FDIC Chair McWilliams advise the committee of the legal authority on which she relied to prevent issuance of the merger RFI (see FSM Report MERGER9).

FHFA Strengthens Affordable-Housing Goals
FHFA today finalized the GSEs’ affordable-housing goals, keeping single-family goals as proposed for 2022-2024. Fannie and Freddie both supported the single-family benchmarks, with Fannie in fact supporting even higher ones.

Daily122221.pdf

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