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On April 1, 2013 the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, the National Credit Union Administration, and the Farm Credit Administration (the Agencies) issued interagency guidance regarding the Flood Disaster Protection Act of 1973 (the FDPA), as amended by the Biggert-Waters Flood Insurance Reform Act of 2012 (the Act). The interagency guidance also provides information regarding the impact of the […]

The Office of the Comptroller of the Currency, the Federal Reserve Board, and the Federal Deposit Insurance Corporation (the Agencies) are proposing to clarify their Interagency Questions and Answers Regarding Community Reinvestment to address several community development issues. The Questions and Answers were first published under the auspices of the Federal Financial Institutions Examination Council (FFIEC) in 1996, and were last revised on March 11, 2010. The Agencies propose to: Revise five questions and answers, […]

We have seen a recent string of enforcement actions from the Consumer Financial Protection Bureau involving deceptive marketing practices. There are lessons for all banks to learn from these actions. What the Actions Had in Common The action was taken by the CFPB in coordination with another federal regulator (FDIC in one and OCC in the other). The action involved huge financial institutions. The action resulted in huge penalties. The actions involved deceptive  acts in […]

On Thursday July 19, 2012, the Office of the Comptroller of the Currency (OCC) and the Consumer Financial Protection Bureau (CFPB) each published releases announcing action against Capital One for Unfair, Deceptive and Abusive Acts or Practices (UDAAP) in violation of Section 5 of the Federal Trade Commission Act. This is the CFPBs first public enforcement action. The bank will pay $150 million in damages to 2.5 million affected consumers. This includes $140 million to […]