regulation-reform

Bankers Must Break the Ice with Regulators and Vice Versa

12/04/12

Banks often choose not to bring questions about products, terms and marketing to regulators, citing fear of retribution from front-line examiners. Creation of the CFPB separates consumer policymaking from examination activities, offering hope for open, clear communication.

[more]

The Goose That Laid the Federal Reserve Note

11/30/12

This newly-discovered, expanded version of Aesop's most famous fable bears an eerie resemblance to the modern day and sheds new light on its tragic moral.

[more]

It's Time to Regulate Prepaid Cards as Bank Accounts

11/29/12

Consumer-focused regulations, in general, should reflect what financial products actually do, not the technicalities of who issues them or what legal status they hold.

[more]

Dodd-Frank Makes a Mockery of 'Plain Language' Movement

11/28/12

We now have two different definitions of a "high-cost" mortgage, as well as a "higher priced" mortgage, and a "higher risk" mortgage. Clearly, Congress failed to practice what it preaches.

[more]

Increasing Business Lending Cap Will Make Credit Unions TBTF

11/27/12

An increased cap would almost certainly lead large institutions, hungry for short-term profits, to take greater risks that they are ill-equipped to handle.

[more]

How Community Banks Can Fight Back Against Basel III

11/26/12

To prove and defend their capital adequacy, community banks must focus on linking the results of stress testing to the core principles that underlie Basel III's standalone ratios.

[more]

Don't Let Payday Lenders Tarnish Mortgage Businesses

11/21/12

All mortgage lenders should voice their objection to the NMLS' efforts to include non-mortgage industries such as pawnbrokers, debt collectors and even used car financing companies in its registry.

[more]

CFPB Must Provide Safe Harbor to All Qualified Mortgages

11/20/12

Providing a safe harbor for only some qualified mortgage loans will swing the stringent credit standard pendulum further in the wrong direction.

[more]

Fincen's New KYC Rule Is Inevitable, but Not Settled

11/20/12

Banks should seize the opportunity to shape the rule in a manner that helps policymakers achieve their AML goals without imposing needless cost and customer pain.

[more]

The Real Threat to Mortgage Lending

11/19/12

Instead of pushing to avoid risk retention or liability for future frauds, banks that want to originate and sell mortgages should focus on containing and rolling back the disparate impact doctrine, which seems sure to savage them.

[more]