Fried Frank的动态

? The Bank Policy Institute, American Bankers Association, The Clearing House and the Consumer Bankers Association have requested more time for banks to comply with the Consumer Financial Protection Bureau data rights rule. The groups have written a joint letter to CFPB director Rohit Chopra. Read the full story at the ?? #openbanking #compliance #datasharing #financialdata #banking #bankingindustry #USbanks #openfinance https://lnkd.in/epsiGSJs

If you’re interested in understanding the very broad views of stakeholders in the bank-fintech ecosystem and where this may all be headed, I recommend reading a sampling of RFI responses from bank, nonbank, everyday Americans, and other interest groups. A close reading of these responses reveals, among other things: — Possible paths for the future of these partnerships, including the role of the Bank Service Company Act — The need for shared terms/common nomenclature — The need for additional nuance in how we risk rate these partnerships — The fact that these partnerships are not all “as a service” — they also include fintechs providing financial services to banks as the primary provider — The importance of these partnerships to the survival of community banks and millions of consumers and businesses — Differences in views between banks and nonbanks regarding what types of partnerships should be considered “high risk” — Differences in views (including across banks) about the role of future regulation and examination of fintechs —The critical importance of delineating roles and responsibilities, risk of loss, etc. at the contract level, understanding these very important details always, and also risk managing the program in continuous alignment with the bank partner’s own risk tolerance —The importance of re-examining the constraints of CSI, and coming up with ways to foster better, more comprehensive communication between banks and third parties —The various very personal stories of consumer harm (including thoughtful comments on the FDIC’s recordkeeping proposal), which should animate all of us to continue innovating and making this environment safer and better. DM if you’d like specific recommendations or further color.

There are a lot of issues packed into the CFPB's forthcoming regulation on personal financial data rights, AKA Section 1033 and open banking. Many of these can be difficult to understand. However, one concept that is quite simple is that all entities in the ecosystem should be held accountable for the way they protect and share consumers' personal information--as banks are today. The linked article delves into the supervisory gap as well as other matters at the top of banks' minds as they await the final rule, anticipated this October.

A follow up to Edelman's Trust Barometer, the new “Insights for the Financial Services Sector” report shows banking up three points since last year and gaining 12 points over the last decade. The solid footing shows that financial institutions have spent decades building their banks on a foundation of trust.

US banking agencies are taking a closer look at fintech partners banks - read this for our thoughts on what could be ahead.

Competition and innovation in the banking industry are at stake with the Lummis-Gillibrand stablecoin bill. Jack Solowey & Jennifer Schulp discuss why a genuine state pathway is crucial for preserving the dual-banking system…

With all the attention now focused on changes at the banking agencies come January, it is easy to overlook that the regulators are still moving ahead with different initiatives in the interim. In Luse Gorman, PC's latest edition of the Bankers' Bulletin, we cover regulatory and enforcement developments from October, including the #CFPB’s open banking rule, the #OCC’s supervision plan for 2025, AI guidance from #NYDFS, the #FDIC’s brokered deposit rule comment period, a novel banking charter issued in Georgia, and more. Check out the Bulletin at the link below.

The Bank Identifier Code (BIC) is indispensable for international transactions, as it identifies the financial institutions involved. Know what is a Bank Identification Code (BIC Code)? https://loom.ly/14GKMPg #financialinstitutions #bank #identification

?? Check out the latest article from The Financial Brand, featuring quotes and insights from our UK-based colleague Jamie Merritt on the topic of open banking and the recent CFPB ruling. ?? https://hubs.ly/Q02YdM2s0

Ever wondered how the Supreme Court's new Major Questions Doctrine might curtail administrative agencies' ability to formulate new regulations? No? That's okay! Read my latest article with the UNC Center for Banking and Finance's Banking Institute Journal here! In it, I explore how the Major Questions Doctrine might pose a significant roadblock to the Consumer Financial Protection Bureau's newly released "Open Banking" rules. Even if you're not interested in banking, I hope it offers a fascinating case study into how this new Doctrine might make it difficult for an agency to write rules in response to an increasingly changing world.