Bank & Thrift Regulation & Enforcement

On May 11, 2018, the beneficial ownership rule became fully effective.  While the rule was finalized on July 16, 2016, compliance was not mandatory until May 11, 2018.  The delay in implementation was to permit covered financial institutions to ready their BSA/AML compliance programs.

In accordance with the rule, a covered financial institution must verify,

In a recent interview, Comptroller of the Currency Joseph Otting, announced the OCC’s plan to “clarify” its support of bank-offered deposit advance products. “Deposit advance products” are typically defined as small-dollar, short-term loans or lines of credit that are to be repaid from the proceeds of the consumer’s next direct deposit.  The WSJ reports that the OCC’s planned announcement will focus on 45-to-90 day loans.

Continue Reading Pay Day Lending: Here Come the Banks!

According to the Federal Deposit Insurance Corporation (“FDIC”), from 2000 to 2008 there were 1,042 de novo community banks newly chartered in the United States.  From 2011-2017, the FDIC received only 30 de novo applications for deposit insurance.  Of those 30 applications received, six have been approved, 10 withdrawn and 14 remain outstanding.  At year end 2017, the number of U.S. banks fell below 5,700 – a number the industry hasn’t seen since the 19th century.  Recently, the FDIC indicated that it has warmed to the idea of accepting de novo bank applications. Now may be the time for interested investors to assess the possibility of entering the community bank industry.

Continue Reading Phoenix Rising: De Novo Bank Formation?

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.

Continue Reading Wells Fargo’s CAMELS Rating Leaked