Barbara S. Mishkin

Barbara S. Mishkin

Ballard Spahr LLP

Contact  |  View Bio  |  RSS

Latest Publications

Share:

ABA comments on CFPB prepaid card proposal

The American Bankers Association has submitted a 46-page comment letter on the CFPB’s proposed prepaid card rule. In the letter, the ABA makes the following key comments: Additional clarity is needed in the definition of the...more

3/27/2015 - American Bankers Association Banking Sector Banks CFPB Consumer Financial Products Prepaid Payment Products

Condominium unit ILSA sales exemption now effective

Effective March 25, 2015, the sale of condominium units are no longer subject to the registration requirements of the Interstate Land Sales Full Disclosure Act (ILSA) under a new exemption. This new exemption applies only to...more

3/27/2015 - Condominiums ILSA Realty Transfer Taxes

Budget amendment introduced to change CFPB appropriations

Another Republican CFPB effort to subject the CFPB to the congressional appropriations policy took the form of an amendment to the Senate’s 2015 Budget Resolution introduced last week by Senator David Perdue. Earlier in...more

3/26/2015 - Appropriations Bill CFPB Federal Budget

OIG adds new audit item to work plan

The Office of Inspector General (OIG) has added a new ongoing CFPB project to its work plan updated as of March 13, 2015. The OIG is auditing the CFPB’s compliance with the Improper Payments Information Act of 2002, as...more

3/26/2015 - Audits CFPB OIG Work Plans

CFPB seeks comments on new information collection plans

The CFPB has published two Federal Register notices seeking comments on its plans to request approval from the Office of Management and Budget for two new generic information collection plans. Comments on both plans are due...more

3/25/2015 - CFPB Credit Reporting Agencies Data Collection Public Comment

KPMG audit finds CFPB budget review controls and corrective action process need improvement

The CFPB has released a report for FY 2014 prepared by KPMG of its independent audit of selected CFPB operations and budget. An annual independent audit is required by the Dodd-Frank Act. The report reflects work performed by...more

3/24/2015 - Audits CFPB KPMG Process Improvement

CFPB’s claims under CFPA survive challenge by for-profit education company but TILA claim held to be time-barred

An Indiana federal court recently granted in part and denied in part the motion of ITT Educational Services, Inc. to dismiss the CFPB’s complaint. As we previously reported, the CFPB’s complaint alleged that ITT engaged in...more

3/19/2015 - CFPA CFPB For Profit Education TILA Tuition

CFPB launches another credit card review

The CFPB has issued another request for information about the credit card market. The request is intended to inform the CFPB’s biennial review of the credit card market mandated by the CARD Act. In October 2013, the CFPB...more

3/19/2015 - CARD Act CFPB Consumer Financial Products Credit Cards

More CFPB reform bills introduced in House

In addition to the bill introduced last week by Republican Congressman Randy Neugebauer that would replace the CFPB’s director with a five-member commission, four other CFPB reform bills have been introduced by Republican...more

3/11/2015 - CFPB Financial Services Committee Pending Legislation

Supervisory or Enforcement Action? Deputy Director Explains How the CFPB Decides

In his prepared remarks for an appearance last month at the Exchequer Club, Consumer Financial Protection Bureau Deputy Director Steven Antonakes discussed the CFPB’s risk-based approach to supervision. (The Exchequer Club’s...more

3/9/2015 - Banking Sector CFPB Enforcement Actions Financial Institutions Nonbank Firms Risk-Based Approaches Supervision

Consumer advocate urges CFPB to ban debt sales with seller disclaimers

We recently wrote about a new report from the National Consumer Law Center that urges the CFPB to ban the collection of debts on which the statute of limitations has run. In a blog post that was published earlier this week on...more

3/6/2015 - Banking Sector Banks CFPB Debt Buyers Debt Collection Statute of Limitations

Liberal and minority caucuses press Director Cordray for payday loan limits

The leaders of four liberal and minority Congressional caucuses have written to Director Cordray to urge the CFPB to adopt “strong protections” for payday loans. The letter was signed by the co-chairs of the Congressional...more

3/6/2015 - CFPB Legislative Agendas Payday Loans Richard Cordray

House Republicans introduce another bill to create commission to run CFPB

House Republicans are making another attempt to replace the CFPB’s director with a five-member commission. A similar attempt passed the House early last year but failed in the Senate. H.R. 1266, introduced earlier this week...more

3/6/2015 - CFPB Legislative Agendas Proposed Legislation

Hensarling establishes new policy for issuing subpoenas and gives CFPB deadline for responding to document requests

Republican Congressman Jeb Hensarling, who chairs the House Financial Services Committee, has established a new policy for using his authority to issue subpoenas to the CFPB and other agency’s subject to the Committee’s...more

3/4/2015 - CFPB Document Requests Financial Services Committee Subpoenas

CFPB’s Credit Union Advisory Council to meet March 12

A meeting of the CFPB’s Credit Union Advisory Council has been scheduled for March 12, 2015 at the CFPB’s offices in Washington, D.C The agenda indicates that the Council will discuss financial education and financial...more

3/4/2015 - CFPB Credit Unions Financial Education Initiatives

Director Cordray to testify on March 3 before House Financial Services Committee

The House Financial Services Committee will hold a hearing tomorrow, March 3, entitled “The Semi-Annual Report of the Bureau of Consumer Financial Protection” at which Director Cordray is expected to testify. The most recent...more

3/2/2015 - CFPB Congressional Investigations & Hearings Financial Services Committee Richard Cordray

CFPB proposes temporary suspension of TILA requirement for credit card issuers to submit card agreements quarterly

The CFPB has issued a proposal to suspend for one year the Truth in Lending Act/Regulation Z requirement for issuers of open-end credit cards to send their credit card agreements to the CFPB quarterly for posting in a public...more

2/26/2015 - CFPB consumer Consumer Financial Products Credit Cards Public Disclosure Regulation Z TILA

Director Cordray speaks to the National Association of Attorneys General

As he has done in prior years, Director Cordray spoke earlier this week to the National Association of Attorneys General. His prepared remarks focused on the familiar theme of “the four Ds” that create obstacles for consumers...more

2/26/2015 - Attorney Generals CFPB Consumer Financial Products Debt Discrimination Enforcement Statistics Richard Cordray Unfair or Deceptive Trade Practices

Supervisory or enforcement action: Deputy Director Antonakes explains how the CFPB decides

In his prepared remarks for an appearance last week at the Exchequer Club, CFPB Deputy Director Steven Antonakes discussed the CFPB’s risk-based approach to supervision. (The Exchequer Club’s members include senior...more

2/24/2015 - Banks CFPB Financial Institutions

Payday loan rulemaking prediction: CFPB will issue proposal this summer

Isaac Boltansky of Compass Point has issued an estimated timeline for the CFPB’s payday loan rulemaking that includes a July 2015 expected date for the CFPB’s release of a proposed rule. Mr. Boltansky estimates that the CFPB...more

2/20/2015 - CFPB Payday Loans Rulemaking Process SBREFA

Trade groups urge CFPB to respond to AFSA vehicle sales finance study

Five prominent industry trade groups sent a letter to the CFPB yesterday seeking “to engage the CFPB in a constructive dialogue” on the study of indirect auto financing commissioned by the American Financial Services...more

2/19/2015 - Automotive Industry Automotive Loans Car Dealerships CFPB Consumer Lenders Trade Associations

FTC sends ECOA report to CFPB

The FTC recently sent a letter to the CFPB reporting on the FTC’s 2014 activities related to compliance with the Equal Credit Opportunity Act and Regulation B. Although the FTC has authority to enforce the ECOA and Reg B as...more

2/19/2015 - CFPB ECOA FTC Nonbank Firms Regulation B

FTC touts partnership with CFPB in annual debt collection report

In the FTC’s 2014 annual letter to the CFPB summarizing the FTC’s debt collection activities, the FTC describes the CFPB as a “valuable partner” with whom the FTC anticipates an “even stronger [partnership] in the...more

2/11/2015 - CFPB Debt Collection FDCPA FTC Rulemaking Process

CFPB issues report on reverse mortgage complaints

The CFPB has issued a “Snapshot of reverse mortgage complaints” covering complaints submitted to the CFPB from December 2011 (when the CFPB began accepting consumer complaints on reverse mortgages) through December 2014....more

2/11/2015 - CFPB Consumer Financial Products Mortgages Public Complaint Reverse Mortgages

NY Regulator and House Republicans weigh in on CFPB payday loan rulemaking

Not surprisingly, letters sent to the CFPB this week by New York Financial Services Superintendent Benjamin Lawsky and by 12 House Republicans urge the CFPB to take very different approaches as it considers payday and...more

2/9/2015 - CFPB Legislative Agendas Payday Loans

345 Results
|
View per page
Page: of 14

All the intelligence you need, in one easy email:

Great! Your first step to building an email digest of JD Supra authors and topics. Log in with LinkedIn so we can start sending your digest...

Sign up for your custom alerts now, using LinkedIn ›

* With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name.
×