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MLA Compliance Deadline For Credit Card Accounts Is Tuesday, October 3

The Military Lending Act (MLA) will apply to credit card accounts starting Tuesday, October 3. The final rule took effect last October but provided a one-year exemption for “credit extended in a credit card account under an...more

Expanded Beneficial Ownership Reporting and AML Duties Under the Corporate Transparency Act

Second of a Two-Part Blog: Anti-Money Laundering Programs Coming to the Legal Profession? Earlier this week, we began our discussion of the proposed Corporate Transparency Act of 2017 (the “Act”), and observed that, if...more

The Corporate Transparency Act: A Proposal to Expand Beneficial Ownership Reporting for Legal Entities, Corporate Formation...

In late June, Representatives Carolyn Maloney and Peter King of New York introduced The Corporate Transparency Act of 2017 (the “Act”). In August, Senators Ron Wyden and Marco Rubio introduced companion legislation in the...more

Businesses continue to face uncertainty, litigation risk in the wake of DOJ’s “inactive” web accessibility rulemaking

On July 20, the Trump Administration posted its first Unified Agenda of Regulatory and Deregulatory Actions. For the first time, the Agenda included a list of “inactive” actions to notify the public of regulations “still...more

FinCEN Takes First Action Against Foreign-Located MSB—“The Virtual Currency Exchange of Choice for Criminals”—For Willfully...

On July 26, FinCEN, in coordination with the U.S. Attorney’s Office for the Northern District of California (“NDCA USAO”), assessed a $110,003,314 civil money penalty against BTC-e a/k/a Canton Business Corporation (“BTC-e”)...more

Federal district court denies state AGs’ request to redirect unused CFPB settlement funds to NAAG

We previously reported that the Connecticut Attorney General, on behalf of himself and the Attorneys General of Indiana, Kansas and Vermont (the “state AGs”), had filed a joint motion to intervene in a CFPB enforcement action...more

A “Death Sentence” for Financial Institutions: the D.C. Circuit Dismisses Andorran Bank Shareholders’ Challenge to FinCEN’s...

On May 23, the federal court of appeals for the District of Columbia Circuit rejected an appeal by the majority shareholders in Banca Privada d’Andorra S.A. (“BPA”) regarding claims that FinCEN violated the Administrative...more

CFPB’s Office of Servicemember Affairs Issues Annual Report

The CFPB’s Office of Servicemember Affairs (OSA) has issued its fifth annual report to Congress addressing issues raised and complaints submitted by servicemembers, veterans, and their families....more

CFPB and DOJ file submissions opposing state AGs’ proposal to redirect unused settlement funds to NAAG

We previously reported that the Connecticut Attorney General, on behalf of the Attorneys General of Indiana, Kansas and Vermont, (the “state AGs”) had filed a joint motion to intervene in a CFPB enforcement action against...more

CFPB and DOJ directed to address state AGs’ proposal to redirect unused settlement funds to NAAG

We previously reported that the Connecticut Attorney General, on behalf of the Attorneys General of Indiana, Kansas and Vermont, (the “state AGs”) had filed a joint motion to intervene in a CFPB enforcement action to request...more

FDIC Chairman: A “Culture of Compliance” Begins at the Top

In his remarks during last week’s launch of Case Western Reserve School of Law’s Financial Integrity Institute, FDIC Chairman Martin J. Gruenberg spoke on the historical context of today’s BSA/AML regulatory framework and the...more

MLA Website malfunction

According to an announcement posted on the Military Lending Act (“MLA”) Website, “[b]etween February 9, 2017 and February 15, 2017 there was a problem with MLA Multiple Record Requests that prevented 149 request files from...more

2016 Year in Review: Money Laundering (Part Two)

In part two of our review of the 2016 developments in Anti-Money Laundering (AML), the Bank Secrecy Act (BSA), the criminal money laundering statutes, forfeiture, and related issues, we discuss four additional key...more

2016 Year in Review: Money Laundering (Part One)

2016 was a busy year for developments in Anti-Money Laundering (AML), the Bank Secrecy Act (BSA), the criminal money laundering statutes, forfeiture, and related issues. In part one of our year-in-review, we discuss six key...more

GAO report highlights gap in SCRA oversight for private student loans; encourages CFPB to seek additional statutory authority

On November 18, the GAO released a report examining issues related to implementation of the Servicemembers Civil Relief Act (SCRA) interest rate cap for student loans. The Senate Committee on Homeland Security and...more

As part of joint initiative with the CFPB, FTC launches updated, mobile-friendly Military Consumer website

This week, the FTC announced the launch of a redesigned Military Consumer website as part of its joint initiative with the DoD, CFPB and others. Military.Consumer.gov is a financial readiness website designed to help...more

FDIC Releases Revised MLA Exam Procedures and Sets Supervisory Expectations

On October 17, the FDIC released revised interagency Military Lending Act (MLA) examination procedures for use in connection with consumer credit transactions occurring on or after October 3, 2016. The revised procedures...more

CFPB and FFIEC Release Updated MLA Exam Procedures; NCAU Will Accept Reasonable and Good Faith Efforts to Comply

On September 30, the CFPB released updated examination procedures for Military Lending Act (MLA) compliance. Compliance with the final rule amending the MLA, issued by the Department of Defense (DoD) in July 2015, was...more

Third Circuit Holds SCRA Protections Do Not Extend to Servicemember-Owned Businesses

In a unanimous opinion in Davis v. City of Philadelphia, the U.S. Court of Appeals for the Third Circuit has held that Servicemembers Civil Relief Act (SCRA) protections do not extend to a servicemember's solely owned...more

DOJ Requests Further Comments on Web Accessibility Rules

Following years of delay, the U.S. Department of Justice (DOJ) is requesting comment on more than 120 questions regarding the proposed web accessibility rule under Title II of the Americans with Disabilities Act (ADA). Though...more

One-Year Period of SCRA Foreclosure Protection Remains in Effect through 2017

On March 31, 2016, President Obama signed into law the Foreclosure Relief and Extension for Servicemembers Act of 2015, which continues through December 2017 a provision of the Servicemembers Civil Relief Act (SCRA) that...more

Effective Communication with Consumers with Disabilities

The Americans with Disabilities Act (ADA) applies to certain entities providing goods and services to the public. In the context of interactions with the public, mortgage lenders have obligations to ensure that information...more

DOJ Delays Web Accessibility Regulations; Enforcement Actions Continue

The U.S. Department of Justice (DOJ) has published its Fall 2015 Statement of Regulatory Priorities and announced that its much-anticipated rulemaking on web accessibility under the Americans with Disabilities Act (ADA) will...more

Mobile Financial Services and the Underserved

The CFPB recently released a report regarding the use of Mobile Financial Services by underserved populations, including low-income, unbanked, underbanked, and economically vulnerable consumers. The report does not contain...more

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