The seeming intent of this rule is to discourage banks from withholding credit from businesses that are legal, but may be politically disfavored. It has been criticized both by banks (the American Bankers Association described it as "arbitrary and capricious," inconsistent with accepted risk management, and imposing significant compliance costs, that made the proposal "untenable") and by Democratic legislators, such as Maxine Waters, Chair of the House Committee on Financial Services, who…

It was generally anticipated that the CFTC would delegate review of firms' capital models to NFA.

Ms. Brainard offers an example of how credit rejections may be explained, provided that the regulators are willing to accept the explanation. A bank may input data that is similar to, but not identical to, the data of a customer whose application has been rejected, and see if a change in the data results in a change in the credit determination. For that to be an acceptable means for a bank to explain a credit rejection, the regulators must be willing to accept the possibility that it is not…

This seems a nice example of how the regulators might work with a private technology firm to reduce the regulatory risks of a product that on its face seems to provide a meaningful benefit to low income workers who would otherwise have to wait a couple of weeks for their paychecks. On the other hand, it could put a dent in , which would be a loss.