Jeremy T. Rosenblum

Jeremy T. Rosenblum

Ballard Spahr LLP

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CFPB releases more overdraft program data as a prelude to likely rulemaking

The CFPB moved closer to likely rulemaking on overdraft programs with the release late last week of a new report entitled “Data Point: Checking account overdraft.” The report is based on account-level and...more

8/4/2014 - Banks CFPB Checking Accounts FDIC Information Reports OCC Overdraft Fees Regulation E Rulemaking Process

House to hold hearings on “Operation Choke Point”

Two House committees have scheduled hearings this week on “Operation Choke Point,” the coordinated federal multiagency enforcement initiative targeting banks serving online payday lenders and other companies that have raised...more

7/15/2014 - Banks Choke Point Congressional Investigations & Hearings Enforcement Legislative Agendas Legislative Committees Payday Loans

‘Operation Choke Point’ under Fire

"Operation Choke Point," the coordinated multiagency federal effort to choke off banking services to alleged fraudsters (according to its defenders) or politically unpopular industries (according to its detractors), has come...more

6/13/2014 - ACH Payments Administrative Procedure Act Banks CFPB Choke Point Community Financial Services Association DOJ FDIC Fraud OCC Payday Loans

Bankers Win Latest Interchange Battle

The U.S. Court of Appeals for the District of Columbia Circuit recently reversed a lower court decision and upheld the interchange rules adopted by the Federal Reserve Board (FRB) under the so-called Durbin Amendment to the...more

3/27/2014 - Banks Dodd-Frank Durbin Amendment Rules Federal Reserve Interchange Fees

DOJ lawsuit sends warning to banks dealing with online payday lenders, third-party payment processors, other targeted companies

Last month, the CFPB filed its first lawsuit against companies involved in online payday lending. The lawsuit against CashCall and several related companies that funded, purchased, serviced and collected online payday loans...more

1/21/2014 - Banks CFPB Compliance DOJ Internet Lenders Payday Loans Payment Processors Third-Party Risk UDAAP

OCC and FDIC Follow Through on Threat To Kill Deposit Advance Loans

The Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) have carried out their threats in their proposed guidance to kill deposit advance loans. On November 21, 2013, the two...more

12/2/2013 - Banks Deposit Advances FDIC Loans OCC

FDIC Clarifies Position on Bank Payment Processing for Payday Lenders and High-Risk Merchants

Last week, the FDIC issued the latest in a series of Financial Institutions Letters dating back to 2008 on the subject of banks managing third-party risk. This most recent FIL deals with payment processing for third-party...more

10/3/2013 - Banks FDIC Payday Loans

CFPB releases white paper on overdraft programs

Yesterday, just after midnight, the CFPB released its initial data findings from its 15-month (and counting) Study of Overdraft Programs....more

6/13/2013 - Banks CFPB Overdraft Fees

A bad month for payday lenders

February was not a good month for payday lenders. As previously reported, on February 20, CFPB Director Cordray expressed pointed concerns about payday and short-term loan “debt traps” in a speech to the Consumer Advisory...more

3/1/2013 - Banks CFPB Consumer Lenders Lenders Loans Payday Loans Richard Cordray

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