OCC Issues Guidance on “Buy Now, Pay Later” Lending

This article outlines what banks should consider as regulators plan to rescind the 2023 Community Reinvestment Act final rule and to reinstate the prior CRA framework.

Through joint guidance and an information request, federal bank regulators underscored banks’ compliance responsibilities in their banking-as-a-service (BaaS) relationships with third parties. Our Financial Services Team unpacks what financial institutions and their counterparties need to know about navigating this evolving BaaS regulatory terrain.

Our Financial Services & Products Group analyzes the implications of final rules for marketplace lending arrangements from the Office of the Comptroller of the Currency.

The Coronavirus Aid, Relief, and Economic Security (CARES) Act sprawls across 800 pages. Our Financial Services & Products Group delves into the sections that deal specifically with banking and lending.

Our Financial Services & Products Group examines how federal regulators – speaking with a single voice – will view loan modifications during the coronavirus pandemic.