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The Examiner

"A house divided against itself cannot stand."

Abraham Lincoln
Buried this day in 1865 in Springfield, Illinois

Statement by John Ryan on Federal Court Decision in CSBS vs. OCC

“We have received a decision from Judge Dabney Friedrich on Conference of State Bank Supervisors vs. Office of Comptroller of the Currency, a case brought in the U.S. District Court for the District of Columbia. The case involves OCC’s efforts to create a national bank charter for non-depository financial technology firms. Such efforts exceed the OCC’s statutory authority, CSBS argued.  

“I appreciate Judge Friedrich’s consideration and timely decision on this matter. In essence, the Judge decided that the OCC has not made a final decision on proceeding with the fintech charter and, thus, the matter is not yet ripe for consideration. As a result, the Judge did not render a decision on the merits of our case.  

“State regulators continue to supervise a vibrant financial services market of banks and nonbanks alike, promoting access to innovative products while ensuring consumer protection. Indeed, states are actively modernizing financial regulation by moving towards an integrated, 50-state system of licensing and supervision for fintechs and other nonbanks.” 

States Oppose Legislation to Preempt State Authority to Protect Consumers on Student Loans

State financial regulators sent a letter to Rep. Virginia Foxx, chairwoman of the House Committee on Education and the Workforce, opposing provisions of the PROSPER Act (H.R. 4508) that preempt state laws related to student loan servicing. 

CSBS wrote: “As a reflection of their greater accountability to local concerns, every state has enacted laws to protect residents from marketplace and financial abuses—and has developed the regulatory framework, legal tools, and expertise to prevent, deter, and respond to misconduct.”

State financial regulators previously objected to the U.S. Department of Education’s attempt to preempt state authority over student loan servicers and debt collectors on similar grounds. That letter to Education Secretary Betsy DeVos is available here

Gonzales Elected as State Liaison Committee Chairman

The Federal Financial Institutions Examination Council’s (FFIEC) State Liaison Committee (SLC) announced the re-election of Greg Gonzales as its Chairman. The SLC Chairman’s term is a one-year period that begins May 1 and runs until April 30 of the following year. The SLC can re-elect the chairman for additional terms.

Gonzales is the 18th commissioner of the Tennessee Department of Financial Institutions. He began serving in this role in 2005 and was reappointed by Governor Bill Haslam. He has served in the department since 1986. In this position, Gonzales serves as Tennessee’s chief regulatory officer of all state-chartered depository and licensed non-depository financial institutions. Additionally, he has served as assistant commissioner and general counsel for the department. Gonzales is a past Chairman of CSBS, and currently serves on both the Board of Directors of the Tennessee Financial Literacy Commission and a national task force studying how new technologies are affecting the U.S. payment systems. Gonzales has also served on the Board of the Money Transmitter Regulators Association (MTRA) and U.S. Treasury’s Bank Secrecy Act Advisory Group.

Greg Gonzales has been active on the SLC since February 2016, when he was first confirmed by the Conference of State Bank Supervisors (CSBS) to complete a partial term vacancy created by the resignation of Lauren Kingry. On April 1, 2017, Gonzales was reappointed to serve his first two-year term which runs through March 31, 2019.

Face Re-Appointed to FFIEC State Liaison Committee

The Federal Financial Institutions Examination Council (FFIEC) announced the reappointment of Edward “Joe” Face to the FFIEC’s State Liaison Committee (SLC). Face’s SLC reappointment was confirmed by the Council for a two-year term starting May 1, 2018, and continuing through April 30, 2020.

Face has been the Commissioner of Financial Institutions for the Virginia State Corporation Commission's Bureau of Financial Institutions (Bureau) since 1997. The Bureau regulates and supervises almost 1,700 state-chartered financial institutions holding some $75 billion in assets. These institutions include banks, bank holding companies, independent trust companies, savings institutions, credit unions, small loan/consumer finance companies, mortgage lenders and brokers, industrial loan associations, money order sellers/transmitters, debt-counseling agencies, check cashers, motor vehicle title lenders, and payday lenders.

Face has been employed at the Bureau since 1979 when he began work as an examiner. In 1988, Face helped start the American Association of Residential Mortgage Regulators, the national association of state mortgage regulators. He served as the group's first two-term president. He also has served as president of the National Association of Consumer Credit Administrators and the national association of state consumer finance regulators. Face also is a past chairman of the Conference of State Bank Supervisors (CSBS) (2006-2007), the nationwide organization of banking regulators from all 50 states and U.S. territories.

About the SLC

The SLC consists of five representatives of state banking and credit union agencies that supervise financial institutions. Members are designated by the CSBS, ACSSS, NASCUS, and the FFIEC. An SLC member may have his or her two-year term extended by the appointing organization for an additional, two-year term.

The five-member SLC also includes:

  • SLC Chairman Greg Gonzales, Commissioner, Tennessee Department of Financial Institutions, appointed by the CSBS;
  • Tom Fite, Director, Indiana Department of Financial Institutions
  • Mary Hughes, Financial Institutions Bureau Chief of the Idaho Department of Finance, appointed by the National Association of State Credit Union Supervisors (NASCUS); and
  • Caroline Jones, Commissioner of the Texas Department of Savings and Mortgage Lending, appointed by the American Council of State Savings Supervisors (ACSSS).

About the FFIEC

The FFIEC was created by the Federal Financial Institutions Regulatory and Interest Rate Control Act of 1978 to prescribe uniform principles, standards, and report forms for the federal examination of financial institutions, and to make recommendations to promote uniformity in the supervision of financial institutions. It also conducts schools for examiners employed by the five federal member agencies represented on the FFIEC and makes those schools available to employees of state agencies that supervise financial institutions.

The FFIEC currently consists of the following six voting members: a member of the Board of Governors of the Federal Reserve System; the Chairman of the Federal Deposit Insurance Corporation; the Director of the Consumer Financial Protection Bureau; the Comptroller of the Currency; the Chairman of the National Credit Union Administration; and the Chairman of the SLC.

Case Study Competition Winner to be Announced Thursday, May 10

Five student teams from universities across the nation have advanced to the final round of the 2018 Community Bank Case Study Competition. The top three winners will be announced this Thursday, May 10 at 1:45 PM during the CSBS State-Federal Supervisors Symposium in Jacksonville, Fla. The announcement will also be streamed live the CSBS Twitter channel.

The student teams represent the following universities: Eastern Kentucky University, Southeastern Louisiana University, University of Missouri - Kansas City, Ohio State University and York College of Pennsylvania. Their case studies looked at how community banks are using technology to streamline processes and better serve their customers. 

“This year’s competition has been very exciting due to sheer volume and the high quality of case studies,” said CSBS Senior Executive Vice President Michael Stevens. “It is a wonderful way to highlight student work and gain insights to how banks are deploying technology.”

A record number of entrants entered in the fourth year of the competition, which is open to undergraduate students in all fields of study as an opportunity to gain valuable first-hand knowledge of the banking industry. The finalists advanced through two rounds of judging and an original pool of 51 participating teams representing 45 universities. Last year, 33 teams participated.

The student teams compete for an academic scholarship, a chance to get their work published in an academic journal and an opportunity to attend the sixth annual CSBS-Federal Reserve Community Banking Research Conference, held in St. Louis this October.