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Christopher M. Paridon

All Things FinReg

LATEST REGULATORY DEVELOPMENTS IMPACTING
THE FINANCIAL SERVICES INDUSTRY

OCC Issues Final ‘True Lender’ Rule

By Steve Levitan
// October 28, 2020
The Office of the Comptroller of the Currency (OCC) issued a final rule on October 27 that determines when a national bank or federal savings association (bank) makes a loan and is the “true lender” in the context of a partnership between a bank and a third party, such as a marketplace lender. This is a significant regulatory development that warrants the close attention of the national banking community and those who do business with national banks and federal savings associations.
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Topics: Banking, Enforcement, FinTech, Global Regulation and Supervision, Innovation, Lending, Marketplace Lending, Office of the Comptroller of the Currency, Regulation, Regulatory, Supervision and Examination

CFPB Issues Final Rule Extending the Qualified Mortgage ‘GSE Patch’

By Asa J. Herald
// October 21, 2020
The Consumer Financial Protection Bureau (CFPB or Bureau) on October 20 issued a final rule to extend the government-sponsored enterprises patch (GSE Patch), i.e., the “temporary qualified mortgage” exemption within the qualified mortgage/ability-to-repay rule.
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Topics: BCFP, Bureau of Consumer Financial Protection, CFPB, Consumer Financial Protection Bureau, Consumer Financial Services, Dodd-Frank Act, Enforcement, Lending, Mortgage Lending, Regulation, Regulatory, Supervision and Examination

FinCEN Expands AML, Customer Identification Programs, and Beneficial Ownership Requirements to Banks Lacking a Federal Functional Regulator

By Martin Hirschprung
// September 24, 2020
The Financial Crimes Enforcement Network (FinCEN) issued a final rule that requires minimum standards for anti-money laundering (AML) programs for banks lacking a federal functional regulator (the Federal Reserve Board, OCC, FDIC, OTS, NCAU, and SEC), i.e., banks and similar financial institutions that are subject only to state regulation and supervision, and certain international banking entities (collectively, “covered banking entities”).
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Topics: Anti-Money Laundering, Banking, BSA, FDIC, Federal Reserve, FinCEN, OCC, Regulation, Regulatory, Supervision and Examination

COVID-19 Update: CDC Announces a Nationwide Ban on Residential Evictions

By Martin Hirschprung
// September 03, 2020
The Centers for Disease Control and Prevention (CDC) on September 1 issued an order under Section 361 of the Public Health Service Act to temporarily—at least through the end of 2020—halt residential rental evictions for Americans struggling to pay rent due to the coronavirus (COVID-19) pandemic. The CDC states that the ban is necessary to mitigate the spread of COVID-19, a historic threat to public health, by preventing homelessness and facilitating stay-at-home/social distancing directives.
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Topics: Banking, Consumer Financial Services, COVID-19, FHFA, HUD, Regulation, Regulatory, Treasury
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