Federal Reserve Clarifies Access To Master Accounts And Services For Financial Institutions, Including For “Novel Charters” In Final Guidelines

The Federal Reserve Board (“FRB”) has approved final guidelines (“Final Guidelines”) for Federal Reserve Banks (“Reserve Banks”) to use in evaluating requests for master accounts and access to Reserve Bank financial services (“Fed Accounts and Services”).1 The Final Guidelines reflect the comments to and development of two prior proposed guidelines: (i) the initial proposed guidelines, issued on May 11, 2021; and (ii) the supplemental proposed guidelines, issued March 8, 2022 (please see our prior Client […]

By | September 15th, 2022 ||

In Depth: Summary Of Notable Comments To Federal Banking Agencies’ Interagency Proposal To Update Community Reinvestment Act Rules

As we reported in May, the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board (“FRB”) and the Office of the Comptroller of the Currency (“OCC”) (together, the “Agencies”) issued a notice of proposed rulemaking to amend and update the rules implementing the Community Reinvestment Act (“CRA”). The comment period on the proposal ended on August 5. We held off summarizing the comments until most people returned from, hopefully, some restful end-of-summer R&R.

Summary of the Proposal

The proposal […]

By | September 13th, 2022 ||

New York Publishes Proposed Rules On Commercial Financing Disclosures

On September 14, the New York Department of Financial Services (NYDFS) published a notice of proposed rules under New York’s Commercial Financing Disclosure Law (CFDL) (we discussed this previous rulemaking in a blog post here). Under the CFDL, commercial finance companies are required to give consumer-style loan disclosures to potential recipients when a specific offering of finance is extended for certain commercial transactions of $2.5 million or less. We note some items in particular from the latest proposed rule:

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By | September 8th, 2022 ||