Yesterday, the Office of the Comptroller of the Currency (OCC) issued guidance to banks on managing the risks associated with “buy now, pay later” (BNPL) lending. Specifically, the bulletin addresses BNPL loans that are payable in four or fewer installments and carry no finance charges. The stated aim of the OCC’s guidance is to ensure that these loans are offered in a manner that is safe, sound, and compliant with applicable laws and regulations.
On October 24, the Federal Reserve Board (Fed), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the agencies) finally issued their long-awaited final rule modernizing how they assess lenders’ compliance under the Community Reinvestment Act (CRA). The CRA was enacted in 1977 to address systemic inequities in access to credit and encourages banks to meet the credit needs of the entire community, including low- and moderate-income (LMI) communities, consistent with safety and soundness principles. The last meaningful, comprehensive revision to the CRA regulations occurred in 1995.
On April 3, 2019, the Strategic Hub for Innovation and Financial Technology (“FinHub”) released a framework for analyzing the application of U.S. federal securities laws to digital assets (the “Framework”).[1] At the same time, the Division of Corporation Finance (the “Division”) of U.S. Securities and Exchange Commission (the “Commission”) issued a no-action response to
Author Stephen R. Covey has written, “Management is efficiency in climbing the ladder of success; leadership determines whether the ladder is leaning against the right wall.”[1] With the first quarter in full swing, community banks are preparing proxy statements, finalizing annual meeting agendas, and marshaling items for board attention. Now is the perfect time for