Financial Institutions

The OCC Is a Problem Agency

12/19/20

It's time to say it loud and clear: the OCC is a problem agency.

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Regulatory Comments to the OCC on the Fair Access to Financial Services Rule

12/18/20

I submitted comments to the OCC about its proposed rulemaking regarding Fair Access to Financial Services. I previously blogged on the topic here and here.

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Figure's National Banking Charter Application: Illegal and Bad Policy

12/07/20

It's not every day that I write a letter in opposition to the issuance of a bank charter. But that's what I just did. Here is my comment letter to the Office of the Comptroller of the Currency in opposition to the charter application for Figure, which is seeking to operate an uninsured national bank.

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Commercial and Contract Law: Questions, Ideas, Jargon

12/01/20

In the Spring I am teaching a research and writing seminar called Advanced Commercial Law and Contracts. Credit Slips readers have been important resources for project ideas in the past, and I'd appreciate hearing what you have seen out in the world on which you wish there was more research, and/or what you think might make a great exploration for an enterprising student.

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The OCC Stands Up for Fossil Fuels, Gun Makers, Opioid Manufacturers, and Payday Lenders

11/20/20

Those wascally wabbits at OCC are back at it again in the waning light of the Trumpshchina. The OCC has proposed a rule on "Fair Access to Financial Services." 

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OCC Suggests "Fair Access" Rulemaking to Require Banks to Finance the Oil and Gas Industry

08/04/20

Just when you think it can't get more ridiculous... The Office of Comptroller of the Currency, which hasn't taken racially discriminatory lending seriously, is concerned about banks' discriminatory refusal to serve the oil and gas industry.

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No More Bailouts

06/30/20

I have a new white paper out from the Roosevelt Institute's Great Democracy Initiative. The paper, which is co-authored with Lindsay Owens and Ganesh Sitaraman, proposes a standing emergency economic stabilization authority to provide an off-the-shelf immediately available response to common problems that recur in national economic crises.

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As businesses try to recover, it's time for fintechs to get proactive

06/29/20

A spike in demand has led to a bigger emphasis on innovative solutions for the digital payments market.

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Banks can ill afford to get complacent about coronavirus

06/24/20

Business continuity plans should be used constantly, not just when the crisis is at its peak, says the New York Fed’s head of financial services.

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How to Start Closing the Racial Wealth Gap

06/17/20

I have an article out in The American Prospect about How to Start Closing the Racial Wealth Gap. Unlike a lot of writing bemoaning the racial wealth gap, this piece has a concrete reform that could be undertaken on day 1 of a Biden administration without any need for legislation or even notice-and-comment rulemaking.

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