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NYDFS Requests Comment on Presumptions of Control for New York-Regulated Institutions

USA - January 27 2023 On December 20, 2022, the New York Department of Financial Services (“NYDFS”) requested comment on how it applies the presumptions of control in New…

Matthew Bisanz, Kris D. Kully

What to Expect in Banking in 2023

USA - January 24 2023 The end of 2022 saw a few noteworthy proposals and other actions by the US banking regulators. Final rulemakings on some proposals may come in 2023…

Matthew Bisanz

Iowa Targets Out-of-State Bank Partner for Usury, Shedding Light on State’s Interpretation of DIDMCA Opt-Out

USA - January 12 2023 In December, the State of Iowa and the Iowa Division of Banking entered into an Assurance of Discontinuance (“AOD”) with Transportation Alliance Bank…

Francis L. Doorley, Steven M. Kaplan, Eric T. Mitzenmacher, Daniel Pearson

Hitting a Moving Target: Federal Banking Regulators’ Latest Commentary on Crypto-Asset Risks

USA - January 6 2023 On January 3, 2023, the US federal banking regulators released a statement highlighting key risks for banking organizations associated with…

Matthew Bisanz, Joseph A. Castelluccio, Andrew Olmem

CFPB Preliminarily Determines State Commercial Financing Disclosure Laws Not Preempted by Truth in Lending Act

USA - January 5 2023 Small business lenders hoping for federal intervention will be disappointed to learn that the Consumer Financial Protection Bureau (CFPB) has reached…

Krista Cooley, Francis L. Doorley, Steven M. Kaplan, Eric T. Mitzenmacher, Daniel Pearson