Andrea Mitchell

Andrea Mitchell

BuckleySandler LLP

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Latest Publications


Special Alert Update: OCC Revises Guidance Regarding Consumer Protection Requirements to Overdraft Lines and Protection Services

On March 6, 2015, the OCC issued its revised “Deposit-Related Credit” booklet (“DRC booklet”) of the Comptroller’s Handbook, which replaced the “Deposit-Related Consumer Credit” booklet issued on February 11, 2015 (previously...more

3/11/2015 - Banks Consumer Financial Products Deposit Accounts Guidance Update OCC Overdraft Fees

Special Alert: OCC Guidance Applies Consumer Protection Requirements to Overdraft Lines and Protection Services

On February 11, 2015, the OCC issued the “Deposit-Related Consumer Credit” booklet of the Comptroller’s Handbook, which replaced the “Check Credit” booklet. The booklet provides updated guidance and examination procedures...more

2/17/2015 - Banks CFPB Consumer Financial Products Guidance Update OCC Overdraft Fees Regulation Z TILA

Special Alert: CFPB States Supervisory Obligations Trump Nondisclosure Agreements

On January 27, the CFPB issued Compliance Bulletin 2015-01 to remind supervised financial institutions of their obligations concerning the disclosure of confidential supervisory information (CSI) to the CFPB and to third...more

1/29/2015 - CFPB Confidential Information Disclosure Requirements Financial Institutions Non-Disclosure Agreement Nonbank Firms Supervision Third-Party

Special Alert: OCC Updates Third-Party Risk Management Guidance

On October 30, the OCC issued Bulletin 2013-29 to update guidance relating to third-party risk management. The Bulletin, which rescinds OCC Bulletin 2001-47 and OCC Advisory Letter 2000-9, requires banks and federal savings...more

11/4/2013 - Affiliates Banks Contract Drafting Due Diligence Joint Venture OCC Payment Processors Risk Management Subsidiaries

Special Alert: Agencies Issue Joint Statement On Fair Lending Compliance And The CFPB’s ATR/QM Rule

On October 22, the CFPB, the OCC, the FDIC, the Federal Reserve Board, and the NCUA (collectively, the Agencies) issued a joint statement (Interagency Statement) in response to inquiries from creditors concerning their...more

10/24/2013 - Ability-to-Repay CFPB Compliance DOJ ECOA FDIC Federal Reserve HUD Mortgages NCUA OCC Qualified Mortgage Rule Regulation B

SPECIAL ALERT: CFPB Announces First HMDA Enforcement Action, Issues HMDA Guidance

On October 9, the Consumer Financial Protection Bureau (CFPB or Bureau) announced it had assessed civil money penalties totaling $459,000 against two financial institutions—one bank and one nonbank—after examinations...more

10/11/2013 - CFPB Civil Monetary Penalty Enforcement Actions HMDA Mortgages Reporting Requirements

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