Policy Documents

State regulators across the country have a wide diversity of views and supervisory responsibilities over financial institutions that may be (or may be interested in) providing services to cannabis-related legitimate businesses (CRLBs). This…

While the agencies are seeking to provide greater certainty as to the ability of assignees to enforce interest rate provisions of loans originated by banks, CSBS believes, as bank partnerships with nonbanks continue to increase, the “true lender”…

CSBS offers comment on the FDIC's proposed rulemaking in regard to Federal Interest Rate Authority.

State bank regulators view the development of FedNow as the Federal Reserve again laying the necessary foundation to ensure that payment capabilities adapt to innovation and technological advancement.

The proposed national rate cap methodology should not allow the largest institutions to exercise undue influence on the national rate. The local rate cap calculation and process should factor in rates offered by internet-only banks.

The proposed rule states that currently, validation notices, combined with the limited disclosure of consumers’ rights with respect to debt collection, may limit a consumer’s ability to fully exercise their dispute rights.

The Honorable Mitch McConnell Majority Leader United States Senate Washington, DC 20510   The Honorable Charles Schumer Minority Leader United States Senate Washington, DC 20510

State regulators believe this framework has been effective in protecting consumers. The proposed amendments to the Safeguards Rule would bolster the consumer protections ensured by the rule and would not prevent states from imposing stricter…