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Financial Services

Community Reinvestment Act Proposed Rulemaking Update

On December 12, 2019, the Federal Deposit Insurance Corporation (“FDIC”) and the Office of the Comptroller of the Currency (“OCC”) (together, the “Agencies”) issued a joint notice on proposed rulemaking and a request for comment (collectively, the “Proposed Rule”) on proposed updates to their…

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Brokered Deposits Restrictions Proposed Rulemaking Update

On December 12, 2019, the Federal Deposit Insurance Corporation (“FDIC”) issued a notice of proposed rulemaking and a request for comment (collectively, the “Proposed Rule”) with proposed updates to their brokered deposit regulations.1  While the Proposed Rule doesn’t alter the scope of those…

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Banking Marijuana-Related Businesses

On March 21, 2018, Governor Holcomb signed a bill legalizing the sale and use of CBD oil in Indiana.[1]  CBD oil is derived from industrial hemp, which like marijuana, is banned by federal law. This leaves Indiana’s financial institutions asking: can we bank these businesses?

The Legal Landscape …

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Indiana DFI Enforcement Action Against Auto Dealer Underscores the Importance of Ensuring Indirect Lending Partners Understand Consumer Credit Laws

A recent enforcement action by the Indiana Department of Financial Institutions (the “IDFI” or the “Department”) against an auto dealership is a reminder to all dealers engaged in “consumer credit sale” activities in Indiana of the importance of understanding the nuances of the Indiana Uniform…

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