On July 18, 2024, the Consumer Financial Protection Bureau (CFPB) issued a proposed interpretive rule on earned wage access (EWA) products (“Proposed Interpretive Rule”) that, if finalized, would clarify that EWA products are...more
As part of its ongoing attack on bank fees, the Consumer Financial Protection Bureau (CFPB) has issued two proposed rules to regulate fees charged by banks: one on overdraft services, and one on nonsufficient funds fees. The...more
Welcome to the Financial Services Report, holiday style! Banks and non-banks alike started early this year with additions and changes to their regulator stockings. The Senate confirmed Rohit Chopra as the new CFPB Director....more
12/15/2021
/ BSA/AML ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Cards ,
Credit Reports ,
Cryptocurrency ,
Data Collection ,
Department of Justice (DOJ) ,
Dodd-Frank ,
Fair Credit Reporting Act (FCRA) ,
Fair Lending ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
Libor ,
OCC ,
Office of Foreign Assets Control (OFAC) ,
Payment Systems ,
Ransomware ,
Redlining ,
Risk Assessment ,
Student Loans ,
TCPA ,
Technology ,
Truth in Lending Act (TILA) ,
U.S. Treasury ,
UDAAP ,
UDAP
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
The law creating a new California mini-CFPB took effect on January 1, 2021, and a few weeks later, the California Department of Financial Protection and Innovation (DFPI) entered into “first-of-their kind” memoranda of...more
On June 22, 2020, the Consumer Financial Protection Bureau (CFPB or Bureau) published two notices in the Federal Register announcing (1) the launch of a pilot advisory opinion (AO) program (“Pilot AO Program”); and (2) a...more
In this paper, we consider whether educational income share agreements (“ISAs”) are subject to federal and state equal access and anti-discrimination laws. When an ISA provider (“Provider”) sets the terms of an ISA, the...more
EDITOR’S NOTE -
In the words of Willie Wonka: “Wait a minute — strike that, reverse it!” As loyal readers will recall, in our last issue, we tried to stay current in referring to the CFPB by what Mick Mulvaney declared...more
3/11/2019
/ Appeals ,
Arbitration ,
BSA/AML ,
Consumer Financial Protection Bureau (CFPB) ,
Fair Lending ,
FDIC ,
Financial Services Industry ,
Payday Loans ,
TCPA ,
Truth in Lending Act (TILA) ,
Volcker Rule
EDITOR’S NOTE -
Hope you survived all of those awkward Thanksgiving holiday conversations— amazing how divided people are on whether the court got it right in the PHH case, isn’t it? So on we go into the holiday season,...more
12/7/2016
/ Arbitration ,
Article III ,
Blockchain ,
CalOPPA ,
Consent Order ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Credit Card Surcharges ,
Cybersecurity ,
Data Breach ,
Distributed Denial of Service ,
ECOA ,
FDCPA ,
Federal Reserve ,
Federal Trade Commission (FTC) ,
FinTech ,
HMDA ,
HUD ,
LGBTQ ,
Military Lending Act ,
NYDFS ,
OCC ,
OIG ,
Prepaid Payment Products ,
Risk Management ,
SCRA ,
Spokeo v Robins ,
Truth in Lending Act (TILA)
Why another law firm newsletter? Over ten years ago, Will Stern answered that question in the first Editor’s Note of the first Financial Services Report. Some things have changed since then—we no longer print and mail paper...more
3/9/2016
/ Arbitration ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Cards ,
Customer Lists ,
Cybersecurity ,
Debt Collection ,
Department of Justice (DOJ) ,
EU-US Privacy Shield ,
Fair Credit Reporting Act (FCRA) ,
Fair Lending ,
FDIC ,
Federal Reserve ,
Federal Trade Commission (FTC) ,
HMDA ,
Mortgages ,
OCC ,
Payday Loans ,
Preemption ,
Securities and Exchange Commission (SEC) ,
TCPA ,
Truth in Lending Act (TILA)
On April 15, 2015, the Consumer Financial Protection Bureau (“CFPB”) announced a final rule (“Final Rule”) that suspends for one year the requirement under the Truth in Lending Act and implemented by Regulation Z that credit...more
On February 26, 2015, the Consumer Financial Protection Bureau (“CFPB”) published a proposed rule (“Proposed Rule”) that would suspend for one year the requirement that credit card issuers submit their agreements to the CFPB...more
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
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 ,
Truth in Lending Act (TILA) ,
Volcker Rule