Bank Branch Closures and Consolidation: Regulatory and Disclosure Obligations, Fair Lending and CRA Concerns

This program has been cancelled

A live 90-minute premium CLE video webinar with interactive Q&A


Wednesday, May 19, 2021

1:00pm-2:30pm EDT, 10:00am-11:30am PDT

Early Registration Discount Deadline, Friday, April 23, 2021


This CLE webinar will examine litigation, regulatory, and enforcement risks arising out of temporary or permanent bank branch closings and consolidation. The panel will explain the federal laws and regulations banks should consider, especially with respect to fair lending, redlining, and Community Reinvestment Act (CRA) concerns, in implementing a branch consolidation or closure initiative and offer tips for mitigating against such risks.

Description

Banks have closed or consolidated branches at a record pace in recent months due to a combination of factors: increased adoption of online and mobile banking by banks and their customers, bank mergers, and businesses' shutdown during the pandemic. FDIC-insured banks are obligated to adopt and follow a clearly articulated branch closure policy but even neutral policies present risk. With the trend expected to continue in 2021 and beyond, bank counsel must be conversant on branch closures' regulatory implications and the laws that may be implicated when closures adversely impact protected communities.

Listen as our authoritative panel discusses notice, disclosure, and other issues associated with bank branch closures and consolidations and how those issues should be addressed when drafting bank policies and procedures.

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Outline

  1. Factors driving branch closures and consolidation
  2. Notification requirements
    1. Regulators
    2. Customers
  3. SEC disclosures for publicly traded banks and BHCs
  4. Community Reinvestment Act concerns
  5. Fair lending and redlining concerns
  6. Tips on updating internal policies and procedures

Benefits

The panel will review these and other important issues:

  • When is a branch consolidation treated similarly to a branch closure for regulatory purposes?
  • What are the disclosure requirements concerning branch closures, and what are the penalties for noncompliance?
  • How do the CRA and fair lending laws figure into branch closures?
  • What are the key points that should be addressed when drafting policies and procedures on branch closing and consolidation?

Faculty

Gottlieb, Richard
Richard E. Gottlieb

Partner
Manatt Phelps & Phillips

Mr. Gottlieb is leader of the firm’s industry-leading consumer financial services practice. Long recognized as...  |  Read More

Reilly, Joseph
Joseph J. Reilly

Counsel
McGuireWoods

Mr. Reilly has nearly two decades of experience representing financial institutions in a wide variety of regulatory,...  |  Read More