By Andrew A. Turner, J.D.
Evolve Bank & Trust of Memphis, Tenn. has agreed to maintain revised policies, conduct employee training, and compensate victims to resolve Justice Department claims that it discriminated against loan applicants receiving Social Security disability benefits in violation of the Fair Housing Act and Equal Credit Opportunity Act. The FHA prohibits lenders from discriminating on the basis of disability, and the ECOA prohibits lenders from discriminating on the basis of receipt of public assistance.
Bank practices. The Justice Department alleged that mortgage applicants were asked to document their disability and that loan applications were denied if they did not comply. "The requirement that borrowers with a disability provide a letter from a doctor or other information about the borrower’s disability to show that income will continue is an intrusive and burdensome requirement that Evolve imposed on borrowers with a disability and did not impose on other borrowers," according to the Justice Department complaint.
Settlement. The terms of the settlement require Evolve to establish a settlement fund of $86,000 to compensate eligible mortgage loan applicants who were asked to provide a letter from their doctor to document their disability income. Evolve will also be required to conduct training for its underwriters and loan officers, and monitor loan applications to ensure that applicants with disabilities are not asked for a letter from a doctor.
“Loan applicants who rely on disability income should not be treated differently than other applicants,” warned Principal Deputy Assistant Attorney General Vanita Gupta, head of the Justice Department’s Civil Rights Division. “This settlement not only provides restitution for mortgage applicants that were harmed by the bank’s discriminatory practices, but ensures that the bank institutes new, fair policies and trains its staff to implement them, added Federal Reserve Governor Lael Brainard.”
The lawsuit originated with a referral from the Board of Governors of the Federal Reserve System to the Civil Rights Division. Evolve is a member of the Federal Reserve System.
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Thursday, January 28, 2016
Wednesday, January 27, 2016
Payment card chargebacks—half caused by fraud; three-quarters paid by merchants
By J. Preston Carter, J.D., LL.M.
A Working Paper released by the Federal Reserve Bank of Kansas City reveals that about 70 to 80 percent of payment card chargebacks are resolved as merchant liability and that half of all chargebacks are due to fraud. The authors, Fumiko Hayashi, Zach Markiewicz, and Richard J. Sullivan, write that although chargebacks are perceived as one of the major cost components for merchants to accept card payments, little research has been done on them. Their paper—“Chargebacks: Another Payment Card Acceptance Cost for Merchants”—attempts to “fill that gap” by generating detailed statistics on chargebacks in order to describe the current chargeback landscape.
The authors collected data from merchant processors that processed more than 20 percent of all signature-based transactions in the United States. The data revealed that, for Visa and MasterCard transactions, chargebacks merchants receive are, on average, 1.6 basis points (bps) of sales number and 6.5 bps of sales value. About 70 to 80 percent of chargebacks are resolved as merchant liability.
The most common chargeback reason is fraud, the data revealed. This accounts for about 50 percent of the total chargebacks. The merchant fraud loss rate is 0.7 bps in number and 2.6 bps in value. For American Express and Discover transactions, the total and fraud chargeback rates are somewhat lower. For all of the four networks, the total and fraud chargeback rates are significantly higher for card-not-present transactions than for card-present transactions. They also vary by merchant category. The authors note that the fraud results are generally consistent with other available fraud statistics.
For more information about credit and debit cards, subscribe to the Banking and Finance Law Daily.
A Working Paper released by the Federal Reserve Bank of Kansas City reveals that about 70 to 80 percent of payment card chargebacks are resolved as merchant liability and that half of all chargebacks are due to fraud. The authors, Fumiko Hayashi, Zach Markiewicz, and Richard J. Sullivan, write that although chargebacks are perceived as one of the major cost components for merchants to accept card payments, little research has been done on them. Their paper—“Chargebacks: Another Payment Card Acceptance Cost for Merchants”—attempts to “fill that gap” by generating detailed statistics on chargebacks in order to describe the current chargeback landscape.
The authors collected data from merchant processors that processed more than 20 percent of all signature-based transactions in the United States. The data revealed that, for Visa and MasterCard transactions, chargebacks merchants receive are, on average, 1.6 basis points (bps) of sales number and 6.5 bps of sales value. About 70 to 80 percent of chargebacks are resolved as merchant liability.
The most common chargeback reason is fraud, the data revealed. This accounts for about 50 percent of the total chargebacks. The merchant fraud loss rate is 0.7 bps in number and 2.6 bps in value. For American Express and Discover transactions, the total and fraud chargeback rates are somewhat lower. For all of the four networks, the total and fraud chargeback rates are significantly higher for card-not-present transactions than for card-present transactions. They also vary by merchant category. The authors note that the fraud results are generally consistent with other available fraud statistics.
For more information about credit and debit cards, subscribe to the Banking and Finance Law Daily.
Tuesday, January 26, 2016
Mortgage assistance services rule can’t apply to attorneys practicing law
By Richard A. Roth
The Consumer Financial Protection Bureau’s Reg. O—Mortgage Assistance Relief Services (12 CFR Part 1015) cannot be applied to attorneys who are performing services that are part of the licensed practice of law, a federal district court judge has decided. The regulation’s exemptions for attorneys are too narrow because they would permit the CFPB to regulate the practice of law, which the Dodd-Frank Act placed beyond the bureau’s authority. The judge also deferred ruling on the validity of the regulation as a whole until the CFPB and the defending attorneys can offer arguments on the effects of partial invalidity (CFPB v. The Mortgage Law Group, LLC, Jan. 14, 2016, Crabb, B.).
The CFPB essentially inherited Reg O, often referred to as the “MARS Rule,” from the Federal Trade Commission. The Dodd-Frank Act also explicitly denies the bureau the ability to exercise authority over an attorney’s activities that are part of the practice of law in a state in which the attorney is licensed (12 U.S.C. §5517(e)). When the CFPB brought an enforcement suit against two law firms and four individual attorneys, the interaction between the bureau’s authority to regulate mortgage assistance services and the Dodd-Frank Act’s protection of the practice of law came into play.
MARS Rule and exemptions. The CFPB claims that The Mortgage Law Group, LLP, Consumer First Legal Group, LLC, and four associated attorneys violated the MARS Rule by misrepresenting their services, omitting required disclosures, and collecting prohibited advance fees. The Mortgage Law Group is in bankruptcy, but the remaining firm and the four attorneys are contesting the bureau’s claims.
The firm and attorneys would be exempt from the misrepresentation and disclosure rules if:
Rule exceeded CFPB authority. There was no real question about the CFPB’s ability to regulate the activities of attorneys outside of the practice of law, the judge said. That was within the bureau’s statutory authority. The question was whether the limited effect of the regulation’s exemptions meant the bureau was impermissibly regulating the activities of attorneys who were practicing law.
The judge also noted that, since the question was one of whether the bureau had exceeded its authority in adopting a regulation, the analysis was governed by Chevron U.S.A. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984). If the Dodd-Frank Act was clear, the law was to be applied. If the act was ambiguous, the regulation would stand if it was a reasonable interpretation of the act.
The Dodd-Frank Act generally prohibits the CFPB from regulating attorneys when they are practicing law, the judge said, and that prohibition would include trust account activities. However, there is a difference between deciding whether an attorney is practicing law and deciding whether he is complying with state laws—after all, an attorney can provide legal services in ways that violate state laws.
The MARS Rule provisions that conditions exemptions on the attorney’s compliance with state laws thus are too restrictive, the judge decided. The CFPB rule could restrict exemptions to attorneys who were offering servicing as part of the practice of law, but not to attorneys who were in compliance with state laws.
The CFPB’s contrary argument would mean that the bureau was prohibited from regulating attorneys engaged in the practice of law but was able to create an exemption “that swallows the general prohibition.” The Dodd-Frank Act intended to deny the bureau the ability to regulate the practice of law without regard to whether the practice was being carried out legally.
Even if the act was ambiguous, the MARS Rule was an arbitrary and capricious interpretation, the judge continued. There was nothing in the authority of either the FTC or the CFPB that indicated Congress intended the agencies to take on the role of enforcing state laws on the professional conduct of attorneys, which is what the rule would require.
For more information about the CFPB's authority, subscribe to the Banking and Finance Law Daily.
The Consumer Financial Protection Bureau’s Reg. O—Mortgage Assistance Relief Services (12 CFR Part 1015) cannot be applied to attorneys who are performing services that are part of the licensed practice of law, a federal district court judge has decided. The regulation’s exemptions for attorneys are too narrow because they would permit the CFPB to regulate the practice of law, which the Dodd-Frank Act placed beyond the bureau’s authority. The judge also deferred ruling on the validity of the regulation as a whole until the CFPB and the defending attorneys can offer arguments on the effects of partial invalidity (CFPB v. The Mortgage Law Group, LLC, Jan. 14, 2016, Crabb, B.).
The CFPB essentially inherited Reg O, often referred to as the “MARS Rule,” from the Federal Trade Commission. The Dodd-Frank Act also explicitly denies the bureau the ability to exercise authority over an attorney’s activities that are part of the practice of law in a state in which the attorney is licensed (12 U.S.C. §5517(e)). When the CFPB brought an enforcement suit against two law firms and four individual attorneys, the interaction between the bureau’s authority to regulate mortgage assistance services and the Dodd-Frank Act’s protection of the practice of law came into play.
MARS Rule and exemptions. The CFPB claims that The Mortgage Law Group, LLP, Consumer First Legal Group, LLC, and four associated attorneys violated the MARS Rule by misrepresenting their services, omitting required disclosures, and collecting prohibited advance fees. The Mortgage Law Group is in bankruptcy, but the remaining firm and the four attorneys are contesting the bureau’s claims.
The firm and attorneys would be exempt from the misrepresentation and disclosure rules if:
- the services were rendered as part of the practice of law;
- the attorneys were licensed to practice in the state where the consumer lived or the home was located; and
- the attorney complied with all state laws and rules that covered his conduct (12 CFR 1015.7(a)).
Rule exceeded CFPB authority. There was no real question about the CFPB’s ability to regulate the activities of attorneys outside of the practice of law, the judge said. That was within the bureau’s statutory authority. The question was whether the limited effect of the regulation’s exemptions meant the bureau was impermissibly regulating the activities of attorneys who were practicing law.
The judge also noted that, since the question was one of whether the bureau had exceeded its authority in adopting a regulation, the analysis was governed by Chevron U.S.A. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984). If the Dodd-Frank Act was clear, the law was to be applied. If the act was ambiguous, the regulation would stand if it was a reasonable interpretation of the act.
The Dodd-Frank Act generally prohibits the CFPB from regulating attorneys when they are practicing law, the judge said, and that prohibition would include trust account activities. However, there is a difference between deciding whether an attorney is practicing law and deciding whether he is complying with state laws—after all, an attorney can provide legal services in ways that violate state laws.
The MARS Rule provisions that conditions exemptions on the attorney’s compliance with state laws thus are too restrictive, the judge decided. The CFPB rule could restrict exemptions to attorneys who were offering servicing as part of the practice of law, but not to attorneys who were in compliance with state laws.
The CFPB’s contrary argument would mean that the bureau was prohibited from regulating attorneys engaged in the practice of law but was able to create an exemption “that swallows the general prohibition.” The Dodd-Frank Act intended to deny the bureau the ability to regulate the practice of law without regard to whether the practice was being carried out legally.
Even if the act was ambiguous, the MARS Rule was an arbitrary and capricious interpretation, the judge continued. There was nothing in the authority of either the FTC or the CFPB that indicated Congress intended the agencies to take on the role of enforcing state laws on the professional conduct of attorneys, which is what the rule would require.
For more information about the CFPB's authority, subscribe to the Banking and Finance Law Daily.
Monday, January 25, 2016
CFPB’s Civil Penalty Fund victim identification process generally effective, can be enhanced
By Stephanie K. Mann, J.D.
An audit conducted by the Office of Inspector General for the Consumer Financial Protection Bureau found that the bureau’s Civil Penalty Fund victim identification process is generally effective and efficient, but there is room for improvement. The audit was conducted in order to assess the efficiency and effectiveness of the CFPB’s process for identifying victims eligible to receive compensation from the Consumer Financial CPF.
In the context of the audit, efficiency refers to the resources used in the victim identification process and effectiveness refers to correctly identifying eligible victims. The scope of the audit included three cases in which identified eligible victims received fund distributions as of Dec. 31, 2014.
Remedying the harm. Under the Dodd-Frank Act, the bureau can bring enforcement actions against those who violate the law. The CFPB or a court may then require a defendant who has violated the law to remedy the harm caused to consumers paying its victims for the harm it caused and, if applicable, by also paying a civil penalty. The bureau is then required to establish a CPF and to deposit civil penalties that it collects into this fund. These civil penalty funds can be used for payments to any eligible victims who do not receive full compensation for their harm from defendants who harmed them.
The victim identification process includes collecting victim-related data, sorting and validating victim-related data, and developing the final list of eligible victims. In some cases, the Office of Technology and Innovation (T&I) is involved in managing victim-related data.
Enhanced responsibilities. In examining the CPF, the OIG found that the Office of the Chief Financial Officer (OCFO) has established internal controls to facilitate the victim identification process and has implemented the procedures and guidelines set forth in the May 2013 Civil Penalty Fund Rule. While this has led to the victim identification process being generally effective and efficient, the OIG did note an opportunity to enhance the process.
The OIG discovered that the OCFO has not documented the roles and responsibilities of the T&I in the victim identification process. The process is data dependent and in some instances, requires the involvement of T&I to produce preliminary lists of eligible victims. By clearly documenting the roles and responsibilities of all parties involved in the victim identification process, said the OIG, the preliminary lists of victims can be properly maintained and all parties involved in the process can be accountable.
The OIG has therefore suggested that the Chief Financial Officer, in coordination with T&I, update the OCFO’s procedures to document the roles and responsibilities of T&I in the victim identification process. The CFO has concurred with this suggestion.
For more information about CFPB enforcement actions, subscribe to the Banking and Finance Law Daily.
An audit conducted by the Office of Inspector General for the Consumer Financial Protection Bureau found that the bureau’s Civil Penalty Fund victim identification process is generally effective and efficient, but there is room for improvement. The audit was conducted in order to assess the efficiency and effectiveness of the CFPB’s process for identifying victims eligible to receive compensation from the Consumer Financial CPF.
In the context of the audit, efficiency refers to the resources used in the victim identification process and effectiveness refers to correctly identifying eligible victims. The scope of the audit included three cases in which identified eligible victims received fund distributions as of Dec. 31, 2014.
Remedying the harm. Under the Dodd-Frank Act, the bureau can bring enforcement actions against those who violate the law. The CFPB or a court may then require a defendant who has violated the law to remedy the harm caused to consumers paying its victims for the harm it caused and, if applicable, by also paying a civil penalty. The bureau is then required to establish a CPF and to deposit civil penalties that it collects into this fund. These civil penalty funds can be used for payments to any eligible victims who do not receive full compensation for their harm from defendants who harmed them.
The victim identification process includes collecting victim-related data, sorting and validating victim-related data, and developing the final list of eligible victims. In some cases, the Office of Technology and Innovation (T&I) is involved in managing victim-related data.
Enhanced responsibilities. In examining the CPF, the OIG found that the Office of the Chief Financial Officer (OCFO) has established internal controls to facilitate the victim identification process and has implemented the procedures and guidelines set forth in the May 2013 Civil Penalty Fund Rule. While this has led to the victim identification process being generally effective and efficient, the OIG did note an opportunity to enhance the process.
The OIG discovered that the OCFO has not documented the roles and responsibilities of the T&I in the victim identification process. The process is data dependent and in some instances, requires the involvement of T&I to produce preliminary lists of eligible victims. By clearly documenting the roles and responsibilities of all parties involved in the victim identification process, said the OIG, the preliminary lists of victims can be properly maintained and all parties involved in the process can be accountable.
The OIG has therefore suggested that the Chief Financial Officer, in coordination with T&I, update the OCFO’s procedures to document the roles and responsibilities of T&I in the victim identification process. The CFO has concurred with this suggestion.
For more information about CFPB enforcement actions, subscribe to the Banking and Finance Law Daily.
Friday, January 22, 2016
FDIC interim rule would allow ‘well-managed’ small banks to use 18-month cycle
The Federal Deposit Insurance Corporation took two actions at its Jan. 21, 2016, meeting of its board of directors, adopting an interim rule that would allow “well-managed” community banks and thrifts with less than $1 billion in assets to qualify for the 18-month exam cycle, and issuing a revised Notice of Proposed Rulemaking on small bank deposit insurance assessments.
Meaningful regulatory relief. Along with the FDIC, the Federal Reserve Board and Office of the Comptroller of the Currency now plan to allow well-managed community banks and thrifts with less than $1 billion in assets to qualify for the 18-month exam cycle. The interim final rule follows authority granted by Congress in December 2015. The 18-month exam cycle has previously been limited to institutions with less than $500 million in assets. In his remarks before the board, Thomas J. Curry, the Comptroller of the Currency, stated that he hopes the change will “offer meaningful regulatory relief to a large group of community banks and thrifts with very little safety and soundness risk.”
Curry also announced that he had approved an identical interim final rule for institutions supervised by the Office of the Comptroller of the Currency. Curry expects that the 18-month cycle will reduce the burden on well-managed community banks and thrifts as well as allow the banking agencies to focus supervisory resources on institutions that “present capital, managerial, or other issues of significant supervisory concern.”
Revised assessments for small banks. The FDIC is seeking comments on its proposal that would amend the way small banks are assessed for deposit insurance. According to the FDIC release, the proposal would revise the methodology that the FDIC uses to determine risk-based assessments for small banks (those with less than $10 billion in assets) to help ensure that banks that take on greater risks pay more for deposit insurance than their less risky counterparts. The agency issued an initial proposal on this issue in June 2015 (see Banking and Finance Law Daily, June 16, 2015). The updated proposal reflects comments received last year on topics including the calculation of asset growth and the treatment of reciprocal deposits and Federal Home Loan Bank advances. Comments must be received by 30 days following publication of the notice in the Federal Register.
In a statement, Chairman Martin J. Gruenberg said that the agency received almost 500 comments on the proposed rule. According to Gruenberg, the revised proposal “would allow assessments to better differentiate riskier banks from safer banks just as well as last year's proposal, and would allocate the costs of maintaining a strong Deposit Insurance Fund accordingly.” Gruenberg stated that the revised proposal is revenue neutral.
Along with the revised proposal, the FDIC is also publishing an online assessment calculator that will allow institutions to estimate their assessment rates under the revised proposal.
Changes from 2015 proposal. According to the FDIC’s Financial Institution Letter, FIL-7-2016, the new proposal would:
- revise the previously proposed one-year asset growth measure;
- use a brokered deposit ratio; consistent with a number of comments, this ratio would treat reciprocal deposits and Federal Home Loan Bank advances the same way the current system does––rather than the previously proposed core deposit ratio––as a measure in the financial ratios method for calculating assessment rates for all established small banks;
- remove the existing brokered deposit adjustment for established small banks, which currently applies to banks outside Risk Category I; and
- revise the weights assigned to the proposed measures in the financial ratios method based upon a re-estimation of the underlying statistical model.
This story previously appeared in the Banking and Finance Law Daily.
Thursday, January 21, 2016
"Subprime, buy-here, pay-here dealer" settles CFPB charges
By Katalina M. Bianco, J.D.
A Greeley, Colo., used car dealer has agreed to settle Consumer Financial Protection Bureau charges relating to its financing activities by paying $700,000 in consumer redress to its customers. Y King S Corp., which does business as Herbies Auto Sales, also agreed to a $100,000 civil penalty, but the penalty will be suspended if the agreed-on redress payments are made.
For more information about CFPB enforcement actions, subscribe to the Banking and Finance Law Daily.
A Greeley, Colo., used car dealer has agreed to settle Consumer Financial Protection Bureau charges relating to its financing activities by paying $700,000 in consumer redress to its customers. Y King S Corp., which does business as Herbies Auto Sales, also agreed to a $100,000 civil penalty, but the penalty will be suspended if the agreed-on redress payments are made.
Herbies Auto Sales is described by the CFPB as a “subprime, buy-here, pay-here dealer,” meaning that the company both sells and finances cars without selling the loans to a third party. The bureau charges that the dealer misrepresented the annual percentage rate that borrowers would pay by not disclosing some finance charges. Herbies has agreed to the entry of a consent order in an administrative proceeding but has not admitted any wrongdoing.
Violations charged. According to the consent order, Herbies advertised a 9.9-percent APR. However, customers who financed their car purchases actually paid a higher APR because the company did not disclose:
- the cost of a required repair warranty as a finance charge;
- the cost of a required GPS payment reminder device as a finance charge; and
- the fact that customers who paid cash could negotiate lower purchase prices.
These practices not only violated Truth in Lending Act disclosure requirements, they also were abusive practices under the Dodd-Frank Act, the CFPB says.
In addition to paying redress, Herbies will have to modify its sales and financing practices. The purchase price of all cars must be clearly posted when financing is offered, and future misrepresentations are barred. Herbies also must give consumers complete information on the car price, APR, finance charges, and loan terms when a loan is offered, and the company must have consumers acknowledge in writing that they received the information no later than when credit is offered.
For more information about CFPB enforcement actions, subscribe to the Banking and Finance Law Daily.
Wednesday, January 20, 2016
Will Metlife’s retail split shed SIFI label?
By John M. Pachkowski, J.D.
Recently, MetLife, Inc. announced that it was considering separating a substantial portion of its U.S. retail segment and currently evaluating structural alternatives for such a separation, including a public offering of shares in an independent, publicly traded company, a spin-off, or a sale. In a press release, the company also noted that it was undertaking preparations to complete the required financial statements and disclosures that would be required for a public offering or spin-off, and that the completion of a transaction taking the U.S. retail segment public would depend on, among other things, the Securities and Exchange Commission filing and review process as well as market conditions.
Once the separation transaction is completed, the new business is to be led by MetLife Executive Vice President Eric Steigerwalt, and the following entities will be included: MetLife Insurance Company USA, General American Life Insurance Company, Metropolitan Tower Life Insurance Company, and several subsidiaries that have reinsured risks underwritten by MetLife Insurance Company USA.
Commenting on the separation plans, Steven A. Kandarian, MetLife chairman, president and CEO, said “This separation would also bring significant benefits to MetLife as we continue to execute our strategy to focus on businesses that have lower capital requirements and greater cash generation potential. In the U.S., it would allow us to focus even more intently on our group business, where we have long been the market leader. Globally, we will continue to do business in a mix of mature and emerging markets to drive growth and generate attractive returns.”
Metlife’s separation plans come roughly 13 months after the company was formally designated a nonbank systemically important financial institution (SIFI) by the Financial Stability Oversight Council in December 2014, and about a year since the insurance company filed a federal lawsuit, in January 2015, seeking to have the SIFI label removed.
The announcement of the separation plans is similar to efforts, announced by General Electric Company in April 2015, to sell its subsidiary General Electric Capital Corporation as a means to shed the SIFI designation that FSOC placed on GE Capital in July 2013.
For more information about systemically important financial institutions/SIFIs, subscribe to the Banking and Finance Law Daily.
Recently, MetLife, Inc. announced that it was considering separating a substantial portion of its U.S. retail segment and currently evaluating structural alternatives for such a separation, including a public offering of shares in an independent, publicly traded company, a spin-off, or a sale. In a press release, the company also noted that it was undertaking preparations to complete the required financial statements and disclosures that would be required for a public offering or spin-off, and that the completion of a transaction taking the U.S. retail segment public would depend on, among other things, the Securities and Exchange Commission filing and review process as well as market conditions.
Once the separation transaction is completed, the new business is to be led by MetLife Executive Vice President Eric Steigerwalt, and the following entities will be included: MetLife Insurance Company USA, General American Life Insurance Company, Metropolitan Tower Life Insurance Company, and several subsidiaries that have reinsured risks underwritten by MetLife Insurance Company USA.
Commenting on the separation plans, Steven A. Kandarian, MetLife chairman, president and CEO, said “This separation would also bring significant benefits to MetLife as we continue to execute our strategy to focus on businesses that have lower capital requirements and greater cash generation potential. In the U.S., it would allow us to focus even more intently on our group business, where we have long been the market leader. Globally, we will continue to do business in a mix of mature and emerging markets to drive growth and generate attractive returns.”
Metlife’s separation plans come roughly 13 months after the company was formally designated a nonbank systemically important financial institution (SIFI) by the Financial Stability Oversight Council in December 2014, and about a year since the insurance company filed a federal lawsuit, in January 2015, seeking to have the SIFI label removed.
The announcement of the separation plans is similar to efforts, announced by General Electric Company in April 2015, to sell its subsidiary General Electric Capital Corporation as a means to shed the SIFI designation that FSOC placed on GE Capital in July 2013.
For more information about systemically important financial institutions/SIFIs, subscribe to the Banking and Finance Law Daily.
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