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Staff Analysis
FAQ: Executive Order on Ensuring Accountability for all Agencies
March 14, 2025
On February 18, 2025, President Trump issued an executive order titled Ensuring Accountability for All Agencies (Independent Agency EO or EO).
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Staff Analysis
FAQ: Executive Order on Implementing DOGE Deregulatory Initiative
February 28, 2025
On February 19, 2025, President Trump issued an executive order titled "Ensuring Lawful Governance and Implementing the President's 'Department of Government Efficiency' Deregulatory Initiative" (Deregulation EO). The executive order—one of several issued by the Trump Administration to downsize and curb the power of Federal agencies—aims to focus regulatory agencies on activities that are "squarely authorized" by Federal law.
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Staff Analysis
Pause of Agency Grant, Loan, and Other Financial Assistance Programs
February 05, 2025
<span style="letter-spacing: 0.15pt; line-height: 107%;">ABA released a summary of the Administration's funding pause directives and the ensuing litigation by state attorneys general and a consortium of non-profit, healthcare, and small business organizations.</span>
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Staff Analysis
FAQ on Presidential Regulatory Freeze Memorandum
January 23, 2025
On January 20, 2025, President Trump issued 60-day regulatory freeze memorandum pausing new and in-process regulations.
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Staff Analysis
Analysis of the Joint Statement and Request for Information on Bank-Fintech Arrangements Involving Banking Products Distributed to Consumers and Businesses
August 09, 2024
On July 25, 2024, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (collectively, the agencies) issued two documents that address "banking as a service" (BaaS), embedded finance and other arrangements through which banks make available deposit, payment, or lending products that fintechs market, distribute, or otherwise provide to consumers or businesses (also known as end users).
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Staff Analysis
10 Takeaways on Third-Party Risk Management Guidance
August 11, 2023
The new guidance, which became effective when issued, rescinds and replaces each agency's prior individual guidance on this topic.
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Comment Letter
ABA Letter to OCC on Proposal to Rescind the 2020 Rule
October 29, 2021
The American Bankers Association (ABA) welcomes the opportunity to respond to the Office of the Comptroller of the Currency's (OCC) proposal to rescind the agency's 2020 rule implementing the Community Reinvestment Act (the 2020 Rule) and replace it with a rule that largely tracks the agency's 1995 Rule, as amended (1995 Rule).; Under this approach, all definitions, performance tests and standards, related data collection, recordkeeping, reporting, and other requirements would revert to those that were in place prior to the issuance of the 2020 Rule.
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Comment Letter
ABA Letter on the Proposed Interagency Guidance on Third-Party Relationships: Risk Management
October 18, 2021
ABA supports this joint effort. This undertaking is especially valuable as a bank's ability to compete in the marketplace depends increasingly on the institution's ability to leverage the expertise of third-party service providers and manage those relationships prudently.
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Comment Letter
Letter to FRB on the ANPR re: CRA Modernization
February 16, 2021
The American Bankers Association is pleased to comment on the Advance Notice of Proposed Rulemaking (ANPR) issued by the Board of Governors of the Federal Reserve System (Federal Reserve) that would modernize the regulations that implement the Community Reinvestment Act of 1977 (CRA).
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Comment Letter
ABA's Letter to OCC Containing a List of Questions re: New CRA Rule
October 05, 2020
The questions were identified by bankers on ABA's CRA Working Group. We share this list in the spirit of collaboration and with the goal of helping the OCC to identify common questions and address information gaps.
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Comment Letter
ABA Letter to FDIC on Third-Party Providers of Technology
September 22, 2020
ABA appreciates the FDIC's willingness to address some of the hurdles, duplication, and costs associated with managing third-party risk. Increasingly, a bank's ability to compete in the marketplace will depend on its ability to leverage the expertise of third-party service providers.
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Staff Analysis
RFI on Standard Setting and Voluntary Certification for Models and Third-Party Providers of Technology and Other Services
July 22, 2020
On July 20, 2020, the FDIC issued a Request for Information (RFI) seeking input on the pros and cons of creating a public/private standards-setting organization (SSO) that would ease the time and burden associated with banks' third-party due diligence obligations.
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Staff Analysis
FDIC/OCC CRA Proposed Rule
December 19, 2019
On December 12, 2019, the FDIC and the OCC proposed major revisions to the regulations implementing the Community Reinvestment Act (CRA).
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Comment Letter
Reforming the Community Reinvestment Act Regulatory Framework
November 15, 2018
Docket ID OCC–2018–0008
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Comment Letter
Comments to CFPB on the 2013 RESPA Servicing Rule
July 10, 2017
The American Bankers Association ('ABA') appreciates the opportunity to comment on the Bureau of Consumer Financial Protection's ('CFPB') plan to assess the 2013 RESPA Servicing Rule. The CFPB is conducting its assessment of the RESPA Servicing Rule pursuant to Section 1022(d) of the Dodd-Frank Act. Section 1022(d) requires that the CFPB evaluate each significant rule it issues and publish a report of that assessment within five years of the rule's effective date. In the case of the Servicing Rules, the CFPB must issue its report by January 10, 2019.