In coordinated actions, the Federal Deposit Insurance Corporation (“FDIC”) and also the workplace regarding the Comptroller for the Currency (“OCC”) announced proposed Supervisory Guidance which will mandate significant changes into the methods of State-chartered non-member banking institutions and nationwide banking institutions providing such items. 1 The Supervisory Guidance is available for remark for 1 month. 2
This customer Alert considers the proposed OCC/FDIC Supervisory Guidance in more detail, and additionally addresses the narrower a reaction to the CFPB research given by the Board of Governors associated with Federal Reserve System (the “Board”) that relates to member that is state-chartered. 3