When Is Supervisory Guidance By Banking Regulators Not A Rule To Live By? When There Is A Rule That Says So.

On September 11, 2018, an interagency statement was issued by the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corp., the National Credit Union Administration and the Consumer Financial Protection Bureau that sought to clarify the limited role of the guidance that they issue....
By: Saul Ewing Arnstein & Lehr LLP

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