Barbara S. Mishkin

Barbara S. Mishkin

Ballard Spahr LLP

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FDIC regional offices issue UDAP guidance on continuous overdraft fees

Based on the CFPB’s rulemaking agenda issued in December 2013, we continue to expect overdraft programs to be the subject of another CFPB white paper and/or an advance notice of proposed rulemaking this year. (In June 2013,...more

4/17/2014 - Banks CFPB Disclosure Requirements FDIC Overdraft Fees Rulemaking Process Service Charges

CFPB testing prepaid card disclosures

Yesterday, the CFPB unveiled two model forms of prepaid card packaging disclosures that it is testing with consumers in Los Angeles. According to its blog post, the CFPB is developing the disclosures in connection with a...more

3/19/2014 - CFPB Credit Cards Disclosure Requirements Prepaid Payment Products

CFPB issues final trial disclosure policy

The CFPB has finalized its policy for exempting individual companies, on a case-by-case basis, from applicable federal disclosure requirements to allow those companies to test trial disclosures. The final policy encourages...more

10/8/2013 - CFPB Consumer Financial Products Disclosure Requirements Dodd-Frank Safe Harbors Waivers

Senate Appropriations Committee votes to “require” CFPB briefings

On July 25, the Senate Appropriations Committee approved report language for the FY 2014 financial services appropriations bill that “directs the Bureau to provide an informal, non-public full briefing, at least annually,...more

7/30/2013 - CFPB Disclosure Requirements Proposed Legislation

Mortgage Banking Update - February 21, 2013

In This Issue: - MERS Has Power To Assign Interest in Deed of Trust, Borrower Can Challenge Assignment of Mortgage, First Circuit Rules - Federal Judge Refuses To Dismiss Arizona Mortgage Class Action Alleging...more

2/21/2013 - CFPB Class Action Debt Collectors Deed of Trust Disclosure Requirements DOJ Fair Lending Fraud Information Sharing Interest Rates Licenses MERS Mortgage Loan Originators

CFPB plans for sharing information with state AGs unchanged in final disclosure rule

In its final rule on Disclosure of Records and Information published last week, the CFPB gave no ground on its position that it has discretionary authority to share confidential information with state attorneys general. This...more

2/20/2013 - Attorney Generals Attorney-Client Privilege CFPB Confidential Information Disclosure Requirements Dodd-Frank Information Sharing

Congress passes bill eliminating ATM fee sticker requirement

The U.S. Senate has joined the House of Representatives in approving a bill (H.R. 4367) amending the Electronic Fund Transfer Act to eliminate the requirement that a fee disclosure be placed in a prominent and conspicuous...more

12/13/2012 - ATMs Disclosure Requirements DOJ EFTA

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