The American Financial Services Association (AFSA) reiterated its support for industrial banks in a comment letter this week to the FDIC. The FDIC’s proposed industrial bank rule would require certain conditions and commitments for financial institutions seeking an industrial bank charter.
AFSA is pleased that the FDIC is again considering industrial bank charters. As the letter stated, “Industrial banks are subject to the same banking laws and are regulated in the same manner as other depository institutions. They are supervised and examined both by the states that charter them and by the FDIC. They are subject to the same safety and soundness, consumer protection, deposit insurance, Community Reinvestment Act, and other requirements as other FDIC-insured depository institutions.”
AFSA’s letter stressed that the FDIC’s rulemaking should be prospective and must exempt existing industrial banks that are currently operating under the present, successful state and federal regulatory regime. AFSA emphasized that there have been no demonstrated supervisory failures, lack of capital support, or operational issues at any industrial bank or parent company that would support changing the current regulatory regime for existing industrial banks. AFSA’s letter also asked that the FDIC’s proposed rules regarding representation on an industrial bank’s board of directors be more balanced.
AFSA Reiterates Support for Industrial Bank Charters
Jul 01, 2020
The American Financial Services Association (AFSA) reiterated its support for industrial banks in a comment letter this week to the FDIC. The FDIC’s proposed industrial bank rule would require certain conditions and commitments… Read the rest
SCOTUS Holds CFPB Structure Violates Separation of Powers
Jun 29, 2020
The Supreme Court today ruled in Selia Law v. CFPB that the structure of the CFPB violates the separation of powers. In an opinion written by Chief Justice John Roberts, the Court held that, “the CFPB Director’s removal protection… Read the rest
Trending Payment Data & Insights During COVID-19 on the Extra Credit Podcast
Jun 25, 2020
In this episode of the AFSA Extra Credit Podcast we talk with Mike Kaplan, CRO with PayNearMe. In mid-May, PNM unveiled a study entitled Consumer Bill Pay Trends During COVID-19. PayNearMe analyzed hundreds of thousands of bill payments made… Read the rest
Identity and Income Fraud in an Increasingly Digitized World
Jun 24, 2020
Join us on June 30 at 1:00 p.m. ET for Identity and Income Fraud in an Increasingly Digitized World, presented by AFSA.
With most dealers going digital and offering off-lot deliveries, it is more important than ever to ensure a consumer’s… Read the rest
CFPB Issues Two NPRMs on Mortgage
Jun 24, 2020
The Consumer Financial Protection Bureau (CFPB) has issued two notices of proposed rulemaking (NPRMs) to amend the Ability to Repay/Qualified Mortgage (ATR-QM) Rule. The first NPRM would extend the sunset date for a temporary category … Read the rest
AFSA Submits Letter to FTC on Endorsement Guides
Jun 23, 2020
This week, AFSA submitted a comment letter to the Federal Trade Commission (FTC) in response to the agency’s request for comment regarding its guidance on advertising, referred to as the Endorsement Guides.
AFSA addressed the need… Read the rest
Class Action Threats Facing the Consumer Finance Industry in the Age of COVID
Jun 22, 2020
Join us on June 25 at 2:00 p.m. ET for Class Action Threats Facing the Consumer Finance Industry in the Age of COVID.
Please join California-based class action defense litigators Anna McLean, Jay Ramsey, Alex Moreno, and Abby Meyer of Sheppard… Read the rest
AFSA Supports Commission Format for CFPB
Jun 19, 2020
The American Financial Services Association (AFSA) yesterday (June 18) joined several other trade associations that represent a wide swath of the American economy in a letter to Sen. Deb Fischer (R-NE) supporting her bill (S. 3990) that … Read the rest
AFSA Statement on CA Assembly Adjournment Without Reconsideration AB 2501
Jun 18, 2020
Today the California Assembly adjourned without reconsidering the “COVID-19 Homeowner, Tenant, and Consumer Relief Law of 2020,” (AB 2501), which if approved would have required creditors to provide up to nine months of vehicle… Read the rest
CFPB Launches Pilot Advisory Opinion Program
Jun 18, 2020
The Consumer Financial Protection Bureau (CFPB) today launched a pilot advisory opinion (AO) program to publicly address regulatory uncertainty in the Bureau’s existing regulations. In a July 2018 letter to the CFPB on guidance,… Read the rest