From: Lexology
Richard E. Gottlieb and Charles E. Washburn, Jr. | Manatt Phelps & Phillips LLP
From: Lexology
Richard E. Gottlieb and Charles E. Washburn, Jr. | Manatt Phelps & Phillips LLP
All five federal banking regulators recently issued an interagency statement, explaining the role of supervisory guidance and describing the agencies’ approach to supervisory guidance.
The message from the Board of Governors of the Federal Reserve System (Federal Reserve), Federal Deposit Insurance Corporation (FDIC), National Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC) and the Bureau of Consumer Financial Protection (CFPB) would suggest that, because supervisory guidance “does not have the force and effect of law,” future use of the Congressional Review Act (CRA) to roll back such guidance may no longer be an option.
What happened