Keith R. Fisher

Keith R. Fisher

Ballard Spahr LLP

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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 Tender Option Bonds

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 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

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

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

Fed Seeks Public Comment on Financial Holding Company Physical Commodities Activities

An Advance Notice of Proposed Rulemaking (ANPR) issued in mid-January by the Federal Reserve Board (the Board) seeks public comment on the scope of permissible physical commodities activities. Such activities have been under...more

3/14/2014 - Bank Holding Company Dodd-Frank Energy Federal Reserve Public Comment

CFPB issues proposal to supervise “larger participant” international money transfer providers

We had been expecting the CFPB’s next “larger participant” proposal to be a rule for the auto finance market. Instead, the CFPB issued a proposed rule yesterday that would allow it to supervise nonbank international money...more

1/24/2014 - Banks CFPB Dodd-Frank Larger Participant Money Transfer Nonbank Firms

Volcker Rule Agencies Issue Interim Final Rule Exempting TruPS-backed CDOs

Last week, the five agencies that jointly issued the final regulation implementing the Volcker Rule (the Final Rule) in December issued an interim final rule (the Interim Rule) that exempts collateralized debt obligations...more

1/23/2014 - American Bankers Association Collateralized Debt Obligations Dodd-Frank Final Rules Financial Regulatory Reform Trust Preferred Securities Volcker Rule

Volcker Rule Promises To Be Godzilla of Bank Regulation

It took almost 3½ years before it finally hatched. And it was big—very big—enormous, in fact. No, it’s not Godzilla. It’s the Volcker Rule. More than two years after the Notice of Proposed Rulemaking, a final rule...more

12/30/2013 - Bank Holding Company Act Banks Dodd-Frank FDIC Federal Reserve OCC Proprietary Trading SEC Volcker Rule

CFPB issues examination procedures for remittance transfers

The Bureau has updated its examination manual with procedures to be followed when examining institutions that make remittance transfers for consumers. A remittance transfer is a wire transfer sent by a consumer in the United...more

10/23/2013 - CFPB Dodd-Frank Electronic Fund Transfer Act Federal Reserve Fraudulent Wire Transfers Regulation E Remittance Transfer Rule UDAAP

The District Court’s ruling in State National Bank of Big Spring v. Lew

When the State National Bank of Big Spring case challenging the constitutionality of several titles of the Dodd-Frank Wall Street Reform & Consumer Protection Act (“Dodd-Frank”) was originally filed in June 2012, I...more

8/7/2013 - CFPB Dodd-Frank FSOC Mortgages Motion to Dismiss Orderly Liquidation Authority Standing

Despite Controversy, Implementation of U.S. Basel III Capital Regime Moves Forward

In June 2012, the Board of Governors of the Federal Reserve System (the “Board”), the Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC) issued proposed regulations that...more

7/26/2013 - Banks Basel III Dodd-Frank FDIC OCC Proposed Regulation

OCC Updates Procedures for Internal Appeals of Supervisory Decisions

The Office of the Comptroller of the Currency (OCC) recently updated its guidance on procedures for internal appeals of supervisory decisions at various levels. The subject matter deals solely with internal appeal procedures...more

6/13/2013 - Dodd-Frank Fair Lending FIRREA Internal Appeals OCC Ombudsman Supervisors

A CFPB Christmas carol: first coordinated action with states

In the first action of its kind since the agency’s creation, the CFPB, Attorneys General from New Mexico, North Carolina, North Dakota, and Wisconsin, and the Hawaii Office of Consumer Protection joined forces to enjoin a...more

12/28/2012 - Advertising Attorney Generals CFPB Dodd-Frank Payday Loan Debt Solution Inc Payday Loans Penalties Restitution Telemarketing

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