Keith R. Fisher

Keith R. Fisher

Ballard Spahr LLP

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How might the Supreme Court’s decision in Perez v. MBA affect the CFPB?

The U.S. Supreme Court’s recent decision in Perez v. Mortgage Bankers Ass’n invalidated a significant line of D.C. Circuit case law known, after the leading case, as the Paralyzed Veterans doctrine. A case involving a series...more

4/8/2015 - Administrative Procedure Act CFPB Dodd-Frank DOL Mortgage Loan Officer Paralyzed Veterans Doctrine Perez v Mortage Bankers Assoc Rulemaking Process SCOTUS Title X Wage and Hour

New York's Lawsky Proposes SOX-Style Personal Accountability for Anti-Money Laundering, Foreign Asset Compliance

It is, by now, common practice for financial institutions (and other businesses as well) to adopt and maintain comprehensive and costly Anti-Money Laundering (AML) and Office of Foreign Assets Control (OFAC) compliance...more

3/18/2015 - Anti-Money Laundering Banking Sector Chief Compliance Officers Financial Institutions NYDFS OFAC

First Salvo by New Congress To Roll Back Dodd-Frank

The House of Representatives recently passed, by a vote of 271-154, legislation that includes a delay in the implementation of the Volcker Rule until 2019. The proposed change would add two years to the maximum extension...more

1/22/2015 - Dodd-Frank Federal Reserve Legislative Agendas Pending Legislation Time Extensions Volcker Rule

Federal Reserve Issues Second Extension of Volcker Compliance Date, Previews Final Extension Next Year

The Board of Governors of the Federal Reserve System (the Board) recently issued an order granting the second of three statutorily permitted one-year extensions for compliance by banking entities with the requirements of the...more

1/7/2015 - Bank Holding Company Banks Covered Funds Federal Reserve Foreign Banks Prudential Regulation Authority Time Extensions Volcker Rule

CFPB Proposes Sweeping Changes for Prepaid Cards

The Consumer Financial Protection Bureau has issued an 870-page proposal for prepaid cards (including 156 pages of actual proposed rules) that mandates new disclosures, error resolution procedures, consumer liability limits...more

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

Regulators Decline to Exempt TOBs from Risk Retention Rule but Add Helpful Revisions and Clarifications

Although regulators have rebuffed industry efforts to have tender option bonds (TOBs) exempted from the final credit risk retention rule (the CRRR), they have nevertheless provided some helpful changes and clarifications that...more

11/3/2014 - ABS Asset-Backed Securities Dodd-Frank Municipal Bonds Risk Retention Securities Exchange Act

CFPB Joins Forces with FDIC on Spanish-Language Tool to Prevent Senior Financial Abuse

Recently the CFPB joined the FDIC’s program against financial abuse of senior citizens by cooperating on the creation of a Spanish language tool for Hispanic seniors. We have previously blogged about the CFPB’s initiatives to...more

11/3/2014 - CFPB FDIC Financial Abuse

Regulators Adopt Risk Retention Rule with Few Changes

A final credit risk retention rule was recently issued with respect to asset-backed securities (ABS) by the prudential bank regulators (the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance...more

10/29/2014 - Asset-Backed Securities Collateralized Loan Obligations Dodd-Frank FDIC Federal Reserve OCC Risk Retention SEC Securities

CFPB’s Rulemaking Process Gets Good Report Card from OIG Report with Only Minor Criticisms

A September 29, 2014 Report of the Joint Federal Reserve/CFPB Office of the Inspector General (OIG) concluded that the CFPB’s rulemaking process generally complies with the requirements of Section 1100G of the Dodd-Frank...more

10/8/2014 - Amended Regulation Banks CFPB Consent Order Dodd-Frank Enforcement Actions FHFA GSE Mortgage Servicing Rules OIG Rulemaking Process Small Business

New FAQ on Volcker Rule CEO Attestation Requirement

The five agencies that jointly issued the final Volcker Rule last December recently added to their existing list of “frequently asked questions” (FAQs) a new item addressing the attestation requirement applicable to CEOs of...more

9/22/2014 - Attestation Deadlines Banks CEOs FBOs Volcker Rule

CFPB finalizes rule to supervise larger participant international money transfer providers

The CFPB has issued a final rule that will allow it to supervise nonbank international money transfer providers that qualify as “larger participants” in the international money transfer market. Consistent with the proposed...more

9/18/2014 - CFPB EFTA Final Rules Money Transfer Nonbank Firms Regulation E

New Larger Participant Rule Enhances Supervision of Remittance Transfer Rule Requirements

The Consumer Financial Protection Bureau recently finalized a larger participant rule for nonbank international money transfer providers and left it largely unchanged from the rule as originally proposed in January. The new...more

9/17/2014 - CFPB Dodd-Frank EFTA Money Transfer Nonbank Firms Regulation E

OCC Issues Final Rule on Heightened Expectations

According to the final rule recently issued by the Office of the Comptroller of the Currency (OCC) formalizing the agency’s “heightened expectations” supervisory regime, the largest U.S. federally chartered depository...more

9/16/2014 - Banking Sector Banks Board of Directors FDIA Final Rules OCC Risk Management

Is a Uniform Debt Buying Code on Its Way?

The Uniform Law Commission (ULC), a non-partisan organization committed to drafting uniform state laws, has authorized the formation of a committee to study the need for and feasibility of state legislation to address the...more

9/4/2014 - Debt Debt Buyers OCC Uniform Law Commission

Despite FAQs and OCC Interim Examination Procedures, Little Illumination So Far for Volcker Rule Compliance

June 2014 saw the publication of some interagency FAQs on the Volcker Rule (the Rule) and interim procedures from the Office of the Comptroller of the Currency (OCC) for its examiners to use in assessing progress by national...more

8/29/2014 - Banking Sector Banks Compliance Enforcement Guidance FDIC Federal Reserve Foreign Banks OCC Volcker Rule

CFPB, AG’s, secure $92M in debt relief for servicemembers victimized by predatory lending

The CFPB, after an investigation in cooperation with 13 state attorneys general, has entered into a consent order with Colfax Capital Corporation, a California consumer lending company (Colfax), and its wholly-owned...more

8/29/2014 - CFPB Debt Debt Collection Debt-Relief Industry Military Service Members Popular Predatory Lending

House Passes Bill to Fix Privilege Waiver Problem for Nonbanks

A bill (H.R. 5062) recently passed by the House of Representatives would amend the Consumer Financial Protection Act (the CFPA), which is Title X of the Dodd-Frank legislation, to provide protection against waiver of state...more

8/28/2014 - CFPA CFPB Dodd-Frank Nonbank Firms Privilege Waivers Title X

FinCEN Proposes More Extensive Customer Due Diligence Obligations

As part of the U.S. Treasury Department’s ongoing efforts to combat all forms of illicit financial activity, from terrorist financing and sanctions evasion to more traditional financial crimes (including money laundering,...more

8/27/2014 - Covered Banking Entity Covered Financial Institutions Due Diligence FinCEN Rulemaking Process U.S. Treasury

Standard Chartered To Pay $300M To Settle AML Charges in New York

For the second time in two years, Benjamin Lawsky, the Superintendent of the New York State Department of Financial Services (DFS), has settled another matter with Standard Chartered Bank for alleged “anti-money laundering...more

8/25/2014 - Anti-Money Laundering Banks Enforcement Actions Settlement Standard Chartered Bank

FDIC Issues Guidance on Basel III Capital Conservation Buffer for Subchapter S Banks

A recent Financial Institution Letter provides guidance on the FDIC’s methodology when entertaining requests from banks or savings associations organized as Subchapter S corporations (S-corporation banks) to pay dividends to...more

8/15/2014 - Banks Basel Committee Basel III Capital Controls FDIC S-Corporation

OCC consumer protection standards in new Bulletin may influence CFPB Debt Sales Examinations of Banks

As noted in our recent Alert, the Office of the Comptroller of the Currency (OCC) has issued Bulletin 2014-37 on Consumer Debt Sales (the “Bulletin”). The Bulletin addresses the application of consumer protection requirements...more

8/7/2014 - Banks CFPB Debt OCC

Comptroller of the Currency Publishes Guidance on Debt Sales Arrangements and Agreements

The Office of the Comptroller of the Currency’s (OCC’s) new Bulletin 2014-37 on Consumer Debt Sales represents the agency’s latest guidance on this topic since providing a written statement a year ago to the Senate...more


CFPB and federal banking regulators increase focus on cybersecurity

As part of their increased focus on cybersecurity, the CFPB and federal banking are taking steps to raise financial institutions’ awareness about the need for preparedness. On June 24, 2014, the Federal Financial Institutions...more

7/15/2014 - Banks CFPB Cybersecurity FFIEC SEC

Federal Bank Regulators Increase Focus on Cybersecurity

As banking regulators increase their focus on cybersecurity, they are taking steps to raise financial institutions’ awareness about the need for preparedness. On June 24, 2014, the Federal Financial Institutions Examination...more

7/14/2014 - Banks Cybersecurity FFIEC

OIG updated work plan adds focus to information security, compensation, and distribution of civil penalty funds

The most notable items added by the Office of Inspector General (OIG) to its work plan, updated as of July 7, 2014, are audits of the CFPB’s information security program, pay and compensation program, and distribution of...more

7/14/2014 - Audits CFPB Civil Penalty Fund Cybersecurity Dodd-Frank Federal Reserve OIG Popular

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