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Acting Comptroller of the Currency Discusses OCC’s Regulatory Agenda

In recent remarks delivered at the U.S. Chamber of Commerce Capital Markets Summit, Acting Comptroller of the Currency, Rodney E. Hood, outlined the OCC’s strategic priorities for building a resilient and revitalized federal banking system.  Addressing an audience that included leaders from across the financial and business sectors, Acting Comptroller…

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CFPB Issues Guidance Emphasizing the Importance for Banks to Maintain Sufficient Proof of Customers’ Affirmative Consent to Overdraft Services

In recent discussions surrounding banking practices, the issue of overdraft fees, particularly for ATM and one-time debit card transactions, has gained significant attention.  On September 17, 2024, the Consumer Financial Protection Bureau (Bureau) issued Consumer Financial Protection Circular 2024-05 asserting that “[a] bank or credit union can be in violation…

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CFPB Reports Troubling Trends in Credit Card Rewards Programs

On May 9, 2024, the Consumer Financial Protection Bureau (CFPB) issued a new Issue Spotlight regarding growing problems in the credit card rewards program industry. Credit card rewards programs have become increasingly complex in recent years.  Especially for credit cards with high annual fees, a key part of attracting interest…

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