Andrew M. Smith

Andrew M. Smith

Morrison & Foerster LLP

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OCC Issues New Third-Party Risk Management Guidance

On October 30, 2013, the Office of the Comptroller of the Currency (OCC) issued new guidance on risks presented by third-party relationships, entitled “Third-Party Relationships: Risk Management Guidance” (“2013 Bulletin”)....more

11/22/2013 - Banks Board of Directors Due Diligence OCC Reporting Requirements Risk Management Third-Party Risk

Brave New World for Data Furnishers

On September 4, 2013, the Consumer Financial Protection Bureau (“CFPB”) issued a Bulletin warning data furnishers that they face potential disciplinary action if they do not properly review information submitted to the credit...more

9/10/2013 - Banks CFPB Compliance Creditors Data Protection Debt Collectors FCRA Nonbank Firms

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