Bank Charters Archives

Comments to Federal Reserve Board Regarding Guidelines for Evaluating Account and Service Requests

April 22, 2022

The Center for Responsible Lending, National Community Reinvestment Coalition, the National Consumer Law Center, on behalf of its low-income clients, and Arthur E. Wilmarth, Jr., Professor Emeritus of Law at George Washington University Law School appreciate the opportunity to comment on the Board of Governors of the Federal Reserve System’s (the Board) supplemental notice and…

Consumer Advocate Groups Call On FDIC To Reject Ford Credit’s ILC Charter Application

August 25, 2022

Ford Motor Company should be denied deposit insurance for its proposed new Ford Credit industrial loan company charter, the National Community Reinvestment Coalition, the National Consumer Law Center, Americans for Financial Reform Education Fund, and the Center for Responsible Lending wrote to the Federal Deposit Insurance Corporation on Wednesday.

Petition to the FDIC Regarding the Community Reinvestment Act Examination of TAB

June 30, 2022

The petition reflects the overwhelming public view that predatory rent-a-bank loans trap borrowers in long debt cycles and disguise loans that are illegal, and thus these loans do not meet the convenience and needs of the community. We believe that these business practices should be taken into account in assessing TAB Bank’s performance under the CRA.

Comments to the FDIC Regarding Parent Companies of Industrial Banks and Industrial Loan Companies

July 1, 2020

Consumer and civil rights groups write to strongly oppose the Federal Deposit Insurance Corporation (FDIC)’s proposed rule on Parent Companies of Industrial Banks and Industrial Loan Companies (proposal or proposed rule) as well as the agency’s approval of new ILC charters. While these actions raise a number of concerns, our comments focus on the dramatic…

Letter to U.S. Treasury Opposing Bank Charter for Stablecoin Issuers

October 28, 2021

Organizations write to express opposition to a bank charter for stablecoin issuers that would give them preemption rights without the full obligations and oversight required for insured depository banks.

Letter to the OCC Regarding Figure Bank, National Association: Charter Application

December 7, 2020

Comment from the National Community Reinvestment Coalition, the National Consumer Law Center® and the Center for Responsible Lending opposing the application from Figure Technologies for a national bank charter and to establish Figure Bank.

Group Letter to the OCC Regarding the Partnership Between Blue Ridge Bank and Mentorworks

April 20, 2021

The undersigned organizations write to the Office of the Comptroller of the Currency to raise serious concerns regarding a federally chartered national bank under your supervisory jurisdiction: Blue Ridge Bank

Comments to the FDIC Regarding Small Dollar Lending

January 22, 2019

Comments of the Center for Responsible Lending and National Consumer Law Center (on behalf of its low income clients), joined by Americans for Financial Reform Education Fund, The Leadership Conference on Civil and Human Rights, and NAACP in response to the FDIC’s request for information (RFI) on small-dollar lending

Comments to the FDIC on Standard Setting and Voluntary Certification for Models and Third-Party Providers of Technology and Other Services

September 22, 2020

Comments in response to the Federal Deposit Insurance Corp.’s (FDIC) request for information on Standard Setting and Voluntary Certification for Models and Third-Party Providers of Technology and Other Services

Comment to CSBS Regarding Draft Model Law Language for MSBs

November 5, 2019

Comment to the Conference of State Bank Supervisors re: Draft Model Law Language for MSBs Request for Comment

Group Comments on Proposed Guidelines for Evaluating Account and Service Requests

July 12, 2021

Comments of the National Consumer Law Center, Center for Responsible Lending, and National Community Reinvestment Coalition to the Board of Governors of the Federal Reserve System on the Proposed Guidelines for Evaluating Account and Service Requests.

Comment Letter Regarding Deposit Insurance Application from Rakuten Bank America

February 19, 2021

National organizations maintain that Rakuten's application for deposit insurance for an Industrial Loan Charter (ILC) would not accord with safety and soundness standards for banks and has not demonstrated a significant commitment to meeting the convenience and needs of the community to be served.

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