Bank & Thrift Regulation & Enforcement

Please join us for a complimentary half-day conference presented by the Financial Institutions Group of Vedder Price.

When & Where

Wednesday, May 9, 2018
7:45 a.m.–Noon (CT)

Chicago Club
81 East Van Buren Street
Chicago, IL 60605

Keynote Speaker:

Alberto J. Paracchini
President and Chief Executive Officer
Byline Bank

Topics

Mergers & Acquisitions and Capital

The Wall Street Journal recently reported that the management component of the CAMELS rating for Wells Fargo Bank, NA had been downgraded to a “3” during 2017.  A “3” rating of management means that the capabilities of management or the board of directors “may be insufficient for the type, size or condition of the institution.”  At best, a “3” rating of management equates to a C minus on a report card.

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The Community Reinvestment Act (CRA) was enacted in 1977 to prevent redlining and to encourage banks and savings associations (collectively, banks) to help meet the credit needs of all segments of their communities, including low- and moderate-income neighborhoods and individuals.  Today, CRA and its implementing regulations require federal banking regulators to assess the record of each bank in fulfilling its obligation to the community and to consider that record in evaluating and approving applications for charters, bank mergers, acquisitions, and branch openings.

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On December 21, 2017, under the direction of Acting Director Mick Mulvaney, the Consumer Financial Protection Bureau (the “CFPB”) announced that it intends to reopen the rulemaking process to reconsider various aspects of the CFPB’s 2015 Home Mortgage Disclosure Act Rule (the “HMDA Rule”). In reopening the rulemaking process for the HMDA Rule, the CFPB intends to reconsider (i) the institutional and transactional coverage tests and (ii) certain other aspects of the HMDA Rule’s discretionary data points. 
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On October 12, 2017, the OCC issued OCC Bulletin 2017-40 announcing the release of its Policies and Procedures Manual 5000-43 (PPM 5000-43), which outlines the OCC’s policy and framework for how the agency determines Community Reinvestment Act (CRA) ratings when there’s evidence of discriminatory or other illegal credit practices directly related to a bank’s CRA