#Wells Fargo – Federal Financial Analytics

17 01, 2023

DAILY011723

Eliza Allen2023-01-17T17:03:48-05:00January 17th, 2023|2- Daily Briefing|

FinCEN Opens Beneficial-Ownership Reports to Public Comment

Likely furthering its effort to garner greater public buy-in for its beneficial ownership information (BOI) standards, FinCEN is now requesting public comment on these reports.

CFPB Presses Consumers, Employees to Action

In a post today, the CFPB double-downed on its recent precedent-setting enforcement action against Wells Fargo (see Client Report CONSUMER46).

Breaking Up Won’t Be Hard to Do

In a high-impact speech today, Acting Comptroller Hsu expressly threatens that the OCC will not stop at the kind of growth restrictions imposed on Wells Fargo (see Client Report CORPGOV26) or the CFPB’s fines (see Client Report CONSUMER46) if a large bank is a repeat offender in safety-and-soundness arenas.

Fed Begins Big-Bank Physical/Transition Financial Climate Risk Analysis

The Fed today announced a two module structure for its upcoming GSIB pilot climate scenario analysis, kicking off a process to identify the data, governance, and processes banks need to manage the financial risks related to physical and transition climate events.

Daily011723.pdf…

21 12, 2022

FedFin on: Nonbank Enforcement-Order Registry

Arezou Rafikian2022-12-21T16:54:37-05:00December 21st, 2022|The Vault|

The CFPB is proposing to create a public registry of certain enforcement actions that would initially cover nonbanks (including BHCs) with a goal of drawing public and enforcement-agency attention to what the Bureau’s director calls “serial offenders.” …

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

21 12, 2022

CONSUMER47

Eliza Allen2022-12-21T15:27:45-05:00December 21st, 2022|1- Financial Services Management|

Nonbank Enforcement-Order Registry

The CFPB is proposing to create a public registry of certain enforcement actions that would initially cover nonbanks (including BHCs) with a goal of drawing public and enforcement-agency attention to what the Bureau’s director calls “serial offenders.” The new filings would be extensive and likely expensive in terms not just of the filings, but also of the analytical processes needed to ensure accuracy and the internal controls assuring officers making requisite attestations that their statements are complete and accurate. Public disclosure of much in the filings – including information that companies consider confidential – would make it easier for other enforcement agencies to identify institutions that may also have violated their own standards as well as alert state and federal banking agencies to entities under their supervision with potential compliance and risk-management shortcomings.

CONSUMER47.pdf…

20 12, 2022

DAILY122022

Eliza Allen2022-12-20T17:18:34-05:00December 20th, 2022|2- Daily Briefing|

CFPB Reaches Massive, Policy-Setting WFC Agreement

The CFPB today reached a landmark and perhaps even unprecedented $3.7 billion settlement with Wells Fargo on an array of “surprise-fee” and bad-practice allegations. Because of the scope of this action and Director Chopra’s plans to use it as grounds for still greater penalties against WFC, we will shortly provide clients with an in-depth analysis of its policy and strategic implications.

Despite Fears, FSB Finds NBFIs Sound In 2021

Although the FSB’s most recent NBFI report (see Client Report NBFI2) and FSOC’s new annual update (see Client Report FSOC28) cite investment funds as a significant concern, FSB’s latest NBFI 2021 monitoring report concludes that most balance-sheet risk measures remained stable. It does note that collective investment vehicles – a category that subsumes MMFs and other funds – experienced the largest growth in the report’s “narrow measure” and continued to have elevated levels of credit intermediation and liquidity and maturity transformation.

Daily122022.pdf…

20 12, 2022

FedFin on: CFPB Crafts New-Style, High-Impact Enforcement Construct

Arezou Rafikian2022-12-20T17:22:32-05:00December 20th, 2022|The Vault|

In this report, we provide an in-depth assessment of the CFPB’s unprecedented $3.7 billion settlement earlier today with Wells Fargo (WFC). In its release, the Bureau notes that it worked with the FRB and OCC to craft this consent agreement; in his remarks, Director Chopra makes it clear that, settled or not, he wants to penalize a “corporate recidivist” by retaining or even tightening the Fed’s 2018 asset-cap (see Client Report CORPGOV26) and doing the same with the OCC’s 2021 mortgage-servicing settlement….

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

20 12, 2022

CONSUMER46

Eliza Allen2022-12-20T15:28:41-05:00December 20th, 2022|5- Client Report|

CFPB Crafts New-Style, High-Impact Enforcement Construct

In this report, we provide an in-depth assessment of the CFPB’s unprecedented $3.7 billion settlement earlier today with Wells Fargo (WFC). In its release, the Bureau notes that it worked with the FRB and OCC to craft this consent agreement; in his remarks, Director Chopra makes it clear that, settled or not, he wants to penalize a “corporate recidivist” by retaining or even tightening the Fed’s 2018 asset-cap (see Client Report CORPGOV26) and doing the same with the OCC’s 2021 mortgage-servicing settlement. The case has also reopened calls to revoke WFC’s status as a financial holding company, action authorized in Dodd-Frank (see FSM Report FHC19) that would sharply constrain the company’s non-traditional securities and insurance activities and establish precedent for this penalty in other large-BHC consumer actions. Although WFC does not admit or deny the Bureau’s charges beyond accepting those specific to its jurisdiction, the Bureau has mandated agreement to several provisions that heighten the settlement’s cost to the bank.

CONSUMER46.pdf…

7 11, 2022

DAILY110722

Eliza Allen2022-11-07T17:22:53-05:00November 7th, 2022|2- Daily Briefing|

Toomey Calls for More Fed Transparency

Sen. Toomey (R-PA) continued Republican demands for still more Fed transparency, sharply criticizing the Fed’s Friday proposal to provide some transparency into which institutions are granted master accounts.

Sweeping CFPB Fee Restrictions Now Effective

The Federal Register today includes the CFPB’s circular on Unanticipated Overdraft Fee Assessment Practices and a bulletin now effective on Unfair Returned Deposited Item Fee Assessment Practices.

CFPB Advances Bigtech Market Power Campaign

Continuing its campaign against bigtech’s market power, the Federal Register today includes the CFPB’s notice and request for comment on what fees bigtech payment operators levy on users for violations of acceptable use policies and whether their policies include provisions to restrict user platform access.

Fed Staff Paper Tries To Gauge Social Welfare Impact Of Liquidity, Capital Regs

A new Fed staff study attempts to lay out the social costs and benefits of large-bank liquidity and capital regulation.

Warren Continues Campaign Against Wells Fargo, Zelle

Sen. Warren (D-MA) today continued her campaign against Zelle by sending letters to its parent company and Wells Fargo, taking particular aim at what she deems the latter’s failure to provide adequate claims and reimbursement data and labelling responses to previous letters “insulting.”

Warren Denounces Fed “Culture of Corruption”

Sen. Warren (D-MA) today also continued her campaign against Chairman Powell, sending him a letter alleging “another set of egregious and embarrassing ethics breaches.”

Daily110722.pdf…

29 06, 2022

DAILY062922

Eliza Allen2023-01-24T16:00:53-05:00June 29th, 2022|2- Daily Briefing|

FRB-Cleveland Study: Small-Business Finance Availability Shows Continuing Disparate Impact

The Federal Reserve Bank of Cleveland today published the results of the Small Business Credit Survey, finding that small businesses owned by people of color were far less likely to have recovered to pre-pandemic levels than their white counterparts, due in part to continuing gaps in financial access.

GOP Renews Demand for Reserve Bank Reform

Picking up on the GOP’s serious concern about Federal Reserve Bank governance expressed when Chairman Powell came before them last week (see Client Report FEDERALRESERVE70), Senate Banking Republicans today sharply criticized the head of the Kansas City Fed for what they call her unresponsiveness and even untruthfulness related to how Reserve Trust achieved payment-system access.

CFPB Report: Credit Line Reductions Harm Vulnerable Borrowers

Continuing the CFPB’s assessment of credit-card finance, Bureau staff today issued a report about the adverse impact that credit line reductions or withdrawals have on consumers, especially those under stress.

HFSC Homeownership Session Fans Partisan Flames

Today’s HFSC hearing on homeownership and inequality was a largely partisan session where each side repeated policy and macroeconomic arguments along party lines about the best ways to govern the nation’s housing market.

IMF Calls for Improvements to Capital Market Regulation

The IMF issued a report today on capital-markets regulation calling for new market liquidity backstops, strengthened CCP risk management, and greater attention to emerging risks to strengthen the regulatory perimeter focus.

Waters Renews Demands to Break Up Big Bad Banks

Following the hearing …

31 05, 2022

DAILY053122

Eliza Allen2023-02-21T13:29:23-05:00May 31st, 2022|2- Daily Briefing|

Basel Finalizes Climate Standards, Advances Those for Crypto

The Basel Committee today announced progress on two key policy concerns: climate risk and cryptoassets. Although it did not release its final action, the Committee has finalized proposed high-level principles for climate-risk management and scenario analysis (see FSM Report CLIMATE12). As we noted in our initial analysis, Basel tried here to give banks and regulators considerable time to ramp up climate-risk analytics and yet make clear that doing so is urgent.

Brown Portrays Wells Fargo as Repeat Offender

Senate Banking Chairman Brown (D-OH) today sent a blistering letter to Wells Fargo CEO Charles Scharf accusing the bank of failing to combat racial and gender discrimination in light of allegations that Wells Fargo conducted fake job interviews for minority and female candidates. The Senator also contends that the bank’s commitment of $150 million to its new refinancing program in response to the chairman’s letter is inadequate.

Daily053122.pdf…

26 04, 2022

CONSUMER40

Max Camateros-Mann2023-03-01T15:52:41-05:00April 26th, 2022|5- Client Report|

Chopra Stands His Ground on Sweeping Agenda, Administrative Process

The Senate Banking Committee’s hearing today with CFPB Director Chopra was a sharply partisan session with little immediate impact on what Mr. Chopra plans to do to achieve his sweeping new vision. Although the debate will have little to no impact on bank-merger policy, much of the session focused on the actions Mr. Chopra took in concert with Acting Chairman Gruenberg to wrest FDIC control from former Chair McWilliams and issue an RFI suggesting significant changes to both merger analytics and bank-resolution policy (see FSM Report MERGER9).

CONSUMER40.PDF…