James H. Mann

James H. Mann

Davis Wright Tremaine LLP

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Federal Financial Institutions Examination Council Releases Cybersecurity Assessment Results: Boards of Directors and Senior...

The Federal Financial Institutions Examination Council (FFIEC) released general observations yesterday from a cybersecurity assessment of over 500 community financial institutions. The cybersecurity assessment evaluated the...more

11/6/2014 - Corporate Officers Cybersecurity Directors FFIEC Financial Institutions Risk Assessment Risk Management

CFPB Proposes No-Action Letter Policy for Innovative Products

The Consumer Financial Protection Bureau has proposed a no-action letter policy under which the agency would issue letters stating that its staff “has no present intention to recommend initiation of an enforcement or...more

10/27/2014 - CFPB Compliance Enforcement Financial Products No-Action Letters UDAAP

Failure of Mandated Disclosures

PLA often posts links to scholarly articles assessing or speculating about the effectiveness, from a consumer-protection standpoint, of disclosure and other regulatory regimes. Past such posts include, for example,...more

7/25/2014 - Compliance Disclosure Requirements Regulation Z

New Form Factors in Cobrand and Private-Label Credit Card Program Agreements

Most current cobrand and private-label agreements involve one or, more usually, two parties that are issuing, branding or developing non-traditional form factors alongside or in lieu of plastic cards. Some of these form...more

5/6/2014 - Brand Credit Cards Mobile Payments Servicing Agreements

College Debit Cards

PLA today posts the GAO’s report, issued last month, analyzing the market for college debit cards and expressing concern about “students’ access to no-fee ATMs, schools’ influence over students’ banking and payment choices,...more

3/7/2014 - Colleges Debit Cards GAO Students

Culture Shock: A Retailer’s Initial Lending Program With a Bank

Many retailers and OEMs have engaged banks to provide private-label credit to their individual and small-business customers, or have joined with banks in offering them cobranded general-purpose credit. Many other...more

12/6/2013 - Banks Lending OEM Retailers Small Business

The Use of Consumer Reports in Online Marketplaces

Online marketplaces increasingly use consumer reports to match consumers with retailers that offer products and services that may be of interest to them....more

7/31/2013 - FCRA Online Platforms

Authorities Regarding GLBA Privacy and the FCRA

One of PLA’s missions is to facilitate knowledge-management for payments practitioners. Pursuant to that mission, PLA is today posting four fundamental, but not always easily accessed, authorities regarding GLBA privacy and...more

3/21/2013 - FCRA GLBA Privacy

Portfolio Finance Reference Materials

PLA today posts the public version of the agreement pursuant to which Chase invested in the Target card portfolio in 2008. Although no longer in effect, this agreement may be a source of useful ideas for future...more

12/5/2012 - JPMorgan Chase

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