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aRTiCLeS

          Having fixed-rate options at the ready helps ag bankers serve as   Acting Comptroller Keith Noreika said at the Philadelphia
          “true relationship managers” with their producer clients, said   Fed’s fintech conference.
          Coates. “That’s one of the ways we try to differentiate ourselves   “What we found is that there could be as high as a three-and-
          from some of our competitors.”
                                                                 a-half percent annual percentage rate increase for consumers
          To view the article visit: https://bankingjournal.aba.  who would be subject to the rule,” Noreika said. “That’s a 25
          com/2017/10/how-bankers-are-providing-more-choices-to-  percent increase in credit costs for people who may live week to
          farmers/                                               week. There’s a real, tangible economic effect that it may have
                                                                 on consumers.”
          Senate Confirms Quarles as                             He said the OCC conducted the study because it wanted to

          Fed’s Top Bank Regulator                               review the effects of the CFPB’s rule – which virtually bans
                                                                 mandatory arbitration agreements in contracts for financial
          The Senate has voted to confirm Randal Quarles as the first-  products and services – on banks and the customers they serve.
          ever vice chairman for supervision of the Federal Reserve Board   “What originally caught my eye...was the potential impact that
          of Governors. Quarles was confirmed to serve on the Fed board   may have on small institutions...that really may face a massive
          by a bipartisan vote of 65 to 32, after which his nomination as   litigation exposure,” he said.
          vice chairman was approved by a voice vote. The position of
          vice chairman for supervision was created in the Dodd-Frank   To read more visit: https://www.occ.gov/publications/
          Act but  has  never  before been  filled.   Senators Hoeven  and   publications-by-type/other-publications-reports/occ-arbitration-
          Heitkamp both voted in favor of the confirmation.      study.pdf

          Pentagon: No Delay for Credit                          CFPB Watchdog: Bureau
          Card Provisions of MLA Rules                           Rushing Unprepared
                                                                 Examiners Into Training
          The Department of Defense denied
          a request by ABA, ICBA and several                     In response to needs for more
          financial trade groups to postpone                     qualified  examiners,  the
          the effective date of the amended                      CFPB is sometimes rushing
          Military Lending Act rules for credit                  unprepared examination  staff
          card accounts. The compliance date for                 through the agency’s examiner
          those accounts was October 3, 2017.                    commissioning      program,
          In a joint comment letter earlier this year, the trade groups   according to a report from the
          highlighted several inconsistencies between the MLA    independent inspector general
          amendments and a subsequent interpretive rule issued by   for the bureau.
          DoD. The groups recommended several changes to ensure   The report found that “management may have encouraged
          that military servicemembers and their families continue to   examiners to proceed through certain components of the ECP
          have access to affordable credit, in addition to requesting the   before being fully prepared in an effort to fulfill workforce
          compliance delay.                                      needs.” To remain with the bureau long-term, examiners must
          The Pentagon’s response indicated that a further interpretive   complete the ECP within five years of reaching the highest non-
          rule addressing some of the concerns is forthcoming, but noted   commissioned examiner grade. But even though examiners are
          that  certain  issues  “are  not…  likely  to  be  addressed  in  any   incentivized to proceed through the ECP, the inspector general
          future guidance.”                                      found  that  managers  pressured  examiners  to  proceed  before
                                                                 they felt ready – which resulted in lower pass rates.

          Arbitration Rule to Raise Cost                         One stumbling block in particular was completion of an
          of Credit 25 Percent, OCC                              examiner-in-chief case study, which had a pass rate of less than
                                                                 50 percent in the summer of 2016, “suggesting that candidates
          Study Finds                                            may be moving to the EIC case study before they are fully
                                                                 prepared.” The report found that the “ineffective controls”
          The OCC has conducted a study finding that the CFPB’s   contributing to pushing unprepared examiners through the
          arbitration rule is likely to increase the cost of credit by about 25   ECP was harming employee morale and taking time away
          percent once lenders factor in the cost of class action litigation,





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