On June 9, 2023, the Federal Reserve Board, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the “Agencies”) published final joint guidance on managing...more
6/21/2023
/ Banking Sector ,
Banks ,
BSA/AML ,
Documentation ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
OCC ,
Oversight Duties ,
Reporting Requirements ,
Risk Management ,
Third-Party ,
Third-Party Risk
On March 13, 2023, Secretary of the Treasury Janet Yellen invoked the systemic risk exemption after receiving recommendations from the board of the Federal Deposit Insurance Corporation (FDIC) and the Federal Reserve Board...more
After a tumultuous few days, Silicon Valley Bridge Bank, N.A. and Signature Bridge Bank, N.A. are open to deposit and loan customers.
Early on Friday, March 10, 2023, bank regulators closed Silicon Valley Bank, the...more
The Department of Justice (DOJ) joined other federal agencies in announcing an increased focus on fair lending issues. On October 22, 2021, DOJ announced a new initiative to crack down on “modern-day” redlining. DOJ is...more
We start this issue with a big, virtual welcome to our new colleague Maria Earley. Maria joined us last month as a partner in our Financial Services and Fintech Groups. She represents financial services and fintech companies...more
9/15/2021
/ Banking Sector ,
BSA/AML ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Department of Justice (DOJ) ,
FDCPA ,
FDIC ,
Federal Reserve ,
FinCEN ,
FinTech ,
Joe Biden ,
Military Lending Act ,
OCC ,
TCPA ,
True Lender
Reflecting the expected heightened regulatory scrutiny of fintechs engaged in bank partnerships, both Illinois and Maine recently enacted laws that place restrictions on fintechs engaged in lending partnerships with banks....more
As spring turns to summer, climate change is on our minds. A new day, a new story about how financial institutions are addressing climate-related risks. In the past few months, six major banks—Bank of America, JPMorgan...more
6/9/2021
/ Anti-Money Laundering ,
Arbitration ,
Artificial Intelligence ,
Banking Sector ,
Bostock v Clayton County Georgia ,
BSA/AML ,
Carbon Emissions ,
Climate Change ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Cryptocurrency ,
Cybersecurity ,
Department of Education ,
Department of Homeland Security (DHS) ,
Eviction ,
FDIC ,
Federal Reserve ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
FinCEN ,
FRB ,
FSOC ,
HOLA ,
Landlords ,
Mortgages ,
NYDFS ,
OCC ,
Popular ,
Student Loans ,
TCPA ,
U.S. Treasury
On January 22, 2021, the Federal Deposit Insurance Corporation (“FDIC”) published its final rule (“Final Rule”) revising and modernizing its regulations related to brokered deposits and the interest rate restrictions that...more
Can you say 0 to 60? Not cars, but pretty much everything to do with financial services. A new year, a new administration, and new challenges for providers. Prior CFPB Director Kraninger is long gone. Acting Director Uejio...more
3/2/2021
/ Arbitration ,
Banking Sector ,
BSA/AML ,
California Consumer Privacy Act (CCPA) ,
Comptroller ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Reporting Agencies ,
Convertible Virtual Currencies (CVCs) ,
Coronavirus/COVID-19 ,
Cybersecurity ,
Data Breach ,
Data Protection ,
Department of Financial Protection and Innovation (DFPI) ,
Digital Assets ,
Dodd-Frank ,
ECOA ,
Fair Credit Reporting Act (FCRA) ,
Fair Lending ,
False Claims Act (FCA) ,
FDIC ,
Federal Reserve ,
Financial Services Industry ,
FinCEN ,
Interest Rates ,
Interpretive Letters ,
Memorandum of Understanding ,
Military Lending Act ,
Minority-Owned Businesses ,
Mortgages ,
OCC ,
Payday Loans ,
PayPal ,
Preemption ,
Regulation D ,
SAR ,
SCOTUS ,
Small Business ,
State Attorneys General ,
TCPA ,
True Lender ,
Truth in Lending Act (TILA) ,
UK ,
Women-Owned Businesses
Happy post-election, post-socially-distanced Thanksgiving, and pre-New Year’s newsletter. Banks, non-banks, and FinTechs can look forward to eight days of announcements from the Biden transition team with their latkes and...more
12/11/2020
/ Arbitration ,
Banking Sector ,
Bitcoin ,
BSA/AML ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Data Breach ,
Debt Collection ,
Fair Credit Reporting Act (FCRA) ,
Fair Lending ,
Federal Savings Associations ,
Financial Services Industry ,
FinCEN ,
FinTech ,
FRB ,
Main Street Lending Programs ,
Mobile Payments ,
OCC ,
Private Attorneys General Act (PAGA) ,
SBA ,
TCPA ,
Third-Party Service Provider
On August 3, 2020, the Consumer Financial Protection Bureau (CFPB) published a Request for Information (RFI) that seeks comment on ways to clarify the Equal Credit Opportunity Act’s (ECOA) implementing regulation, Regulation...more
8/5/2020
/ Artificial Intelligence ,
Banking Sector ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Disparate Impact ,
ECOA ,
Fair Lending ,
Financing ,
Public Assistance ,
Request For Information ,
Small Business Loans
On July 20, 2020, the Office of the Comptroller of the Currency (OCC) issued a notice of proposed rulemaking that would establish when national banks or federal savings associations (collectively, banks) are the “true lender”...more
As Congress scrambles to pass a stimulus package to alleviate financial strain due to the COVID-19 pandemic, federal regulators and some states are directing financial institutions to provide immediate relief. So far,...more
Punxsutawney Phil didn’t see his shadow, so we’re expecting an early spring. Maybe that’s why mini-CFPBs are sprouting or expanding on both coasts. Governor Cuomo announced several key measures impacting financial services...more
On February 10, 2020, the Federal Deposit Insurance Corporation (FDIC) published a proposed rule intended to modernize the regulatory treatment of brokered deposits (Proposed Rule). The Proposed Rule would amend 12 C.F.R....more
On January 31, 2019, the Consumer Financial Protection Bureau (CFPB or Bureau) published a Request for Information (2019 RFI) regarding the consumer credit card market. In accordance with Section 502(a) of the Credit Card...more
On January 3, 2019, the Consumer Financial Protection Bureau (CFPB) announced a settlement with a federal savings bank for alleged violations of the Electronic Fund Transfer Act (EFTA) and Regulation E, as well as alleged...more
Yesterday, September 11, 2018, five federal agencies – the Federal Reserve Board, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency, and the...more
BELTWAY -
The Wayback Machine -
Congress passed, and on May 24, 2018, the president signed into law, the Economic Growth, Regulatory Relief, and Consumer Protection Act (S.2155). The law makes significant changes to...more
6/8/2018
/ Arbitration ,
Auto Lease ,
Banking Sector ,
BSA/AML ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Economic Growth Regulatory Relief and Consumer Protection Act ,
Fair Lending ,
FDCPA ,
FFIEC ,
FinTech ,
GAO ,
General Data Protection Regulation (GDPR) ,
HMDA ,
Securities and Exchange Commission (SEC) ,
SIFMA ,
TCPA
On March 26, 2018, the Consumer Financial Protection Bureau (CFPB or “Bureau”) published a Request for Information (RFI) on the CFPB’s inherited regulations and inherited rulemaking authorities. The RFI is the ninth in a...more
In July 19, 2017 remarks prepared for delivery to the Exchequer Club in Washington, D.C., Acting Comptroller of the Currency Keith Noreika expressed his support for the Office of the Comptroller of the Currency’s (“OCC”)...more
On June 7, 2017, the Office of the Comptroller of the Currency (“OCC”) issued frequently asked questions (“FAQs”) that supplement the OCC’s 2013 guidance entitled “Third-Party Relationships: Risk Management Guidance” (“2013...more
On May 11, 2017, the Federal Deposit Insurance Corporation (FDIC) announced that it had reached settlements with Bank of Lake Mills (Bank) and two of its “institution-affiliated parties” (IAPs)—Freedom Stores, Inc. (FSI) and...more
On March 10, 2017, the Consumer Financial Protection Bureau (CFPB or Bureau) published a Request for Information (2017 RFI) regarding the consumer credit card market. In accordance with Section 502(a) of the Credit Card...more
3/16/2017
/ Banking Sector ,
CARD Act ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Cards ,
Creditors ,
Debt Collection ,
Deferred Interest Products ,
Innovation ,
Online Banking ,
Request For Information ,
Subprime Loans
On November 17, 2016, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) held a field hearing in Salt Lake City, Utah, and published a Request for Information (“RFI”) regarding access to consumer financial account...more