Jeremy Mandell

Jeremy Mandell

Morrison & Foerster LLP

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Overview of the CFPB Prepaid Account Proposed Rule

On November 13, 2014, the Consumer Financial Protection Bureau (“CFPB”) issued a proposed rule to regulate prepaid accounts (the “Proposed Rule”). The Proposed Rule follows the CFPB’s May 2012 advance notice of proposed...more

11/24/2014 - Banking Sector Banks CFPB Prepaid Payment Products Proposed Regulation Regulation E Regulation Z Rulemaking Process TILA

Sweeping Prepaid Card Proposal Issued by CFPB

Today, the Consumer Financial Protection Bureau (“CFPB”) issued its long-awaited proposed rule to further regulate prepaid card products (the “Proposed Rule”). The Proposed Rule was the topic of discussion at a field hearing...more

11/14/2014 - CFPB Prepaid Payment Products Proposed Regulation

FinCEN Rulings Designate Certain Virtual Currency Businesses as Money Transmitters

On October 27, 2014, the Financial Crimes Enforcement Network (“FinCEN”) issued two administrative rulings regarding virtual currency. The first administrative ruling concerns a proposed virtual currency trading and booking...more

10/30/2014 - Bank Secrecy Act Bitcoins Compliance FinCEN Money Transfer Money Transmitter Virtual Currency

Financial Services Report - Fall 2014

In This Issue: - Beltway Report - Bureau Report - Mobile and Emerging Payments Report - Mortgage and Fair Lending Report - Operations Report - Preemption Report - Privacy...more

9/18/2014 - Banking Sector Banks CFPB Data Breach Debt Collection Federal Reserve Lending Mortgages OCC Privacy Policy RESPA Robo-Signing TCPA Volcker Rule

New York DFS Proposes Sweeping Virtual Currency Licensing Scheme

Yesterday, the New York Department of Financial Services (“NYDFS”) issued a proposed rule for public comment setting forth a novel and comprehensive “BitLicense” regulatory scheme for entities engaged in “Virtual Currency...more

7/21/2014 - BitLicense Licenses Licensing Rules Proposed Regulation Public Comment Social Networks Virtual Currency

CFPB to Assume a Larger Role in Virtual Currency Initiatives

On June 26, 2014, the U.S. Government Accountability Office (“GAO”) released a report, entitled “Virtual Currencies: Emerging Regulatory, Law Enforcement, and Consumer Protection Challenges.” The report, delivered earlier to...more

7/8/2014 - CFPB DHS DOJ GAO Information Reports IRS Law Enforcement Legislative Committees Popular Property Tax Virtual Currency

CFPB Further Delays Prepaid Proposed Rule

Industry anticipation continues to grow as the Consumer Financial Protection Bureau (CFPB) announced that its general-purpose reloadable (GPR) prepaid card proposal will now be issued by the end of the summer. Although this...more

6/30/2014 - CFPB Disclosure Legislative Agendas Prepaid Payment Products Proposed Regulation Rulemaking Process

CFPB Issues a Request for Information Related to Mobile Financial Services

Yesterday, the Consumer Financial Protection Bureau (“CFPB”) released a request for information (“RFI”) concerning the use of mobile financial services, specifically among unbanked and underbanked consumers. The RFI was...more

6/13/2014 - CFPB Data Protection Mobile Apps Mobile Banking Request For Information

Financial Services Report, Summer 2014

In This Issue: - Beltway Report - Bureau Report - Mobile Payments - Mortgage and Fair Lending Report - Operations Report - Preemption Report - Privacy Report - Arbitration Report - TCPA...more

6/9/2014 - Banks Cybersecurity Data Protection Encryption Fair Lending FDIC FFIEC Financial Regulatory Reform Heartbleed Mobile Payments Mortgages OCC OIG Popular RESPA SCRA TCPA TILA Volcker Rule

The Fed’s Report on Mobile Financial Services: Slow Growth in Mobile Payments

Earlier this year, the Board of Governors of the Federal Reserve System (“Board”) released a report on its third annual Survey of Consumers’ Use of Mobile Financial Services (the “2013 Survey”). The 2013 Survey are part of...more

5/27/2014 - Mobile Apps Mobile Banking Mobile Devices

Compliance Overseers Under Financial Regulatory Fire

In the wake of the financial crisis, federal and state regulators are increasingly taking action against individuals for alleged compliance lapses inside financial services companies, and recent reports indicate that...more

5/14/2014 - Chief Compliance Officers Compliance Enforcement Actions Financial Regulatory Reform Personal Liability

Financial Regulatory Enforcers Expanding Claims Against Individuals

In the wake of the financial crisis, federal and state regulators are increasingly taking action against individuals for alleged compliance lapses inside financial services companies, and recent reports indicate that...more

5/1/2014 - Chief Compliance Officers Compliance Enforcement Enforcement Actions Officers Personal Liability

FinCEN Issues Additional Clarifications Regarding Bitcoin and other Convertible Virtual Currency Activities

On January 30, 2014, the Financial Crimes Enforcement Network (“FinCEN”) issued two administrative rulings that address the application of Bank Secrecy Act (“BSA”) regulations to convertible virtual currency-related...more

2/7/2014 - Bank Secrecy Act Bitcoins FinCEN Money Services Business Regulation X U.S. Treasury Virtual Currency

CFPB Proposes Definition of Larger Participants for the International Money Transfer Market

On January 23, 2014, the Consumer Financial Protection Bureau (“CFPB”) issued a proposed rule that would define which nonbank covered persons would be designated “larger participants” for purposes of the international money...more

1/27/2014 - CFPB Debt Collection Dodd-Frank Electronic Fund Transfer Act Larger Participant Money Transfer Nonbank Firms Regulation E Student Loans

Financial Services Report - Quarterly News, Winter 2013

Editor’s Note - Stuff didn’t happen this quarter. Lots of it. The federal government didn’t happen for two weeks in October, which caused some to celebrate and others to wring their hands and clamor for a strong,...more

12/11/2013 - Affordable Care Act CARD Act HAMP Healthcare HMDA HOLA HUD

High Quality Liquid Assets

This is not about top-shelf liquor, it is about today’s notice of proposed rulemaking…. At an open meeting today, the Federal Reserve Board (“FRB”) approved a proposed rule implementing a liquidity coverage ratio (“LCR”)...more

10/25/2013 - Banks Basel III FDIC Federal Reserve Liquidity Coverage Ratio OCC

Financial Services Report - Quarterly News, Fall 2013

In This Issue: Beltway Report; Bureau Report; Privacy Report; Mobile Payments Report; Mortgage Report; Operations Report; Preemption Report; Arbitration Report; and TCPA Report. Excerpt from Beltway Report:...more

9/17/2013 - Arbitration EFTA Federal Reserve Mobile Payments Mortgages Preemption Privacy Policy TCPA

D.C. Circuit Hands the CFPB a Setback?

At the end of last week, the U.S. Court of Appeals for the District of Columbia Circuit issued its decision in Noel Canning v. National Labor Relations Board, holding that President Obama’s recess appointments to the National...more

1/30/2013 - Barack Obama Canning v NLRB CFPB NLRB Political Appointments Pro Forma Sessions Recess Appointments Richard Cordray

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