Leonard N. Chanin

Leonard N. Chanin

Morrison & Foerster LLP

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Financial Services Report, Winter 2016

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 CFPB Consent Order Consumer Lenders Credit Card Surcharges Cybersecurity Data Breach Distributed Denial of Service ECOA FDCPA Federal Reserve FinTech FTC HMDA HUD LGBT Military Lending Act NYDFS OCC OIG Prepaid Payment Products Risk Management SCRA Spokeo v Robins Truth in Lending Act (TILA)

CFPB Forgoes Traditional Rulemaking Process in Announcing that the Equal Credit Opportunity Act and Regulation B Prohibit...

Richard Cordray, director of the Consumer Financial Protection Bureau (“CFPB”), issued a letter dated August 30, 2016 (“Cordray Letter”), expressing the CFPB’s views on whether credit discrimination on the basis of gender...more

10/11/2016 - CFPB ECOA Gender Discrimination Gender Identity Regulation B Rulemaking Process Sexual Orientation Discrimination

When CFPB Finds Deception Regardless Of A Lender’s Intent

There is a tendency to think of consumer fraud and misrepresentation as intentional acts that deceive consumers into engaging in transactions that they would not otherwise engage in. A recent case demonstrates that the...more

9/30/2016 - CFPB Financial Institutions Loans Misrepresentation Summary Judgment UDAAP

HUD Releases New Guidance on Limited English Proficiency Discrimination Under the Fair Housing Act

On September 15, 2016, the U.S. Department of Housing and Urban Development (HUD) issued guidance on how the nondiscrimination provisions in the Fair Housing Act (FHA) apply to persons who consider an individual’s “Limited...more

9/23/2016 - Civil Rights Act Discrimination Disparate Impact Executive Orders Fair Housing Act (FHA) HUD Limited English Proficiency (LEP) National Origin Discrimination New Guidance Title VI

Financial Services Report, Fall 2016

Editor’s Note - So much for summer! The weather is cooling, the kids are back to school, and we better not see you wearing white so long after Labor Day! For those of you having a little trouble getting back in the...more

9/21/2016 - Anti-Money Laundering Arbitration CFPB Civil Monetary Penalty Debt Collection Digital Currency EU EU-US Privacy Shield Fair Lending FDIC FinCEN Foreclosure FTC Homeowner Bill of Rights Mortgage Lenders Municipalities OCC Online Banking SEC Standing Tax Revenues TCPA Telemarketing Volcker Rule

A Closer Look at DOD’s New Guidance on the Military Lending Act Regulations

On August 26, 2016, the Department of Defense (“DOD”) issued an interpretive rule (the “Interpretive Rule”) providing guidance on the DOD’s regulations implementing the Military Lending Act (“MLA”). That same day, we...more

9/16/2016 - Credit Agreements Credit Cards Creditors Department of Defense (DOD) EFTs Financial Sector Interpretive Rule Loans Military Annual Percentage Rates (MAPR) Military Lending Act Safe Harbors

Department of Defense Issues New Guidance on Military Lending Act Regulations

On August 26, 2016, the Department of Defense (DOD) issued an interpretive rule providing guidance on the DOD’s regulations implementing the Military Lending Act (MLA). Specifically, the interpretive rule aims to clarify...more

8/29/2016 - Creditors Department of Defense (DOD) Final Rules Interpretive Rule Military Lending Act New Guidance

A Closer Look at the CFPB’s Proposed Short-Term Lending Rule

As we previously reported in our June 3, 2016 client alert, the Consumer Financial Protection Bureau (“CFPB”) has issued a Notice of Proposed Rulemaking for short-term loans (“Proposed Rule”). In this follow-up alert, we take...more

7/21/2016 - Ability-to-Repay CFPB Debt Collection Fair Lending Lending Loans NCUA NPRM Payday Loans Private Right of Action Proposed Rules Request For Information Short-Term Loans UDAAP

Novel Reading Of Statute Widens CFPB Jurisdiction

Tucked away in a seemingly innocuous paragraph in a complaint, the Consumer Financial Protection Bureau has asserted an extraordinary and potentially far-reaching expansion of its authority. On June 6, 2016, the CFPB...more

6/28/2016 - ACH Payments Administrative Authority CFPA CFPB Covered Person Dodd-Frank Jurisdiction Payment Processors Unfair or Deceptive Trade Practices

ACH Debit Transactions – Whose Agent Are You?

Tucked away in a seeming innocuous paragraph in a complaint, the Consumer Financial Protection Bureau (CFPB) has asserted an extraordinary and potentially far-reaching expansion of its authority. On June 6, 2016, the...more

6/24/2016 - ACH Payments CFPA CFPB Covered Providers Debit and Credit Card Transactions Enforcement Actions Payment Processors Third-Party Service Provider Unfair or Deceptive Trade Practices

CFPB Poised to Expand Regulation to Small Business Lending: Expect the Unexpected

Recent initiatives by the Consumer Financial Protection Bureau (“CFPB” or Bureau) to dramatically expand its regulation of small business lending present a confluence of concerns to industry participants. These initiatives...more

5/25/2016 - CFPB Dodd-Frank ECOA Fair Lending Financial Institutions FinTech Loans Non-Bank Lenders Small Business

Penny Proof for Deposits: Federal Banking Regulators Issue Interagency Guidance Regarding Deposit Reconciliation Practices

On May 18, 2016, five federal banking agencies—the Board of Governors of the Federal Reserve System (“Board”), the Consumer Financial Protection Bureau (“CFPB”), the Federal Deposit Insurance Corporation (“FDIC”), the...more

5/23/2016 - Banking Regulators CFPB Deposit Accounts Expedited Funds Availability Act (EFAA) FDIC Federal Reserve Financial Institutions OCC

Supreme Court Affirmation of Hawkins Case Raises More Questions Than It Answers

On March 22, 2016, the Supreme Court of the United States issued an order in Hawkins v. Community Bank of Raymore. An evenly divided Court affirmed the Eighth Circuit decision without issuing an opinion, thereby resolving...more

3/28/2016 - Commercial Loans ECOA Family Status Discrimination Guarantors Hawkins v Community Bank of Raymore Reaffirmation Regulation B SCOTUS Split of Authority Spouses

Financial Services Report, Spring 2016

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 CFPB Credit Cards Customer Lists Cybersecurity Debt Collection DOJ EU-US Privacy Shield Fair Lending FCRA FDIC Federal Reserve FTC HMDA Mortgages OCC Payday Loans Preemption SEC TCPA Truth in Lending Act (TILA)

CFPB Publishes HMDA File Specifications for Data Collected in 2017 and 2018

On February 18, the Consumer Financial Protection Bureau (CFPB) and the Federal Financial Institutions Examination Council (FFIEC) published new “File Specifications” for data to be collected pursuant to the Home Mortgage...more

2/24/2016 - CFPB Data Collection FFIEC HMDA Mortgages

Know Before You Sell: CFPB Letter on “Know Before You Owe” Implementation

In response to a written request from the Mortgage Bankers Association (MBA), Richard Cordray, Director of the Consumer Financial Protection Bureau (CFPB), penned a response dated December 29, 2015, addressing implementation...more

1/12/2016 - CFPB Mortgages TILA-RESPA Integrated Disclosure Rule (TRID)

Big Data, Big Government – Big Trouble? A Hard Look at the Final HMDA Rule

If all goes according to plan, financial institutions will report over 250 million data points related to mortgage loan applications and originations in 2018. If the mortgage market returns to the high volumes seen in 2005,...more

11/30/2015 - CFPB Covered Financial Institutions Covered Transactions Data Collection Fair Lending HMDA Mortgage Loan Originators Popular

HOLY HMDA! CFPB Finalizes Changes to Home Mortgage Disclosure Rule

On October 15, 2015, the CFPB released a final rule amending Regulation C, 12 C.F.R. part 1003, which implements the Home Mortgage Disclosure Act (HMDA). Like the August 2014 proposed rule, the final rule includes changes to...more

10/21/2015 - CFPB Covered Financial Institutions Covered Transactions Data Collection Depository Institutions Disclosure Requirements Final Rules HMDA Mortgage Lenders Mortgage Servicers Mortgages Public Disclosure Regulation C Reporting Requirements

Department of Defense Adopts Significant Changes to Its Military Lending Act Regulations

On July 22, 2015, the Department of Defense (DOD) published sweeping changes to its rules that implement the Military Lending Act (MLA). The amended rules significantly expand the scope of the MLA provisions by covering both...more

8/3/2015 - Active Duty Amended Regulation Borrowers CFPB Consumer Reporting Agencies Credit Cards Creditors Department of Defense (DOD) Disclosure Requirements Finance Charges Lenders Loans Military Lending Act Payday Loans Regulation Z

DOD Adopts Sweeping Changes to Rules Implementing Military Lending Act Provisions

On July 21, 2015, the Department of Defense (DOD) adopted sweeping changes to its rules that implement the Military Lending Act (MLA). The amended rules significantly expand the scope of the MLA provisions by covering both...more

7/22/2015 - Active Duty Borrowers Credit Cards Creditors Department of Defense (DOD) Final Rules Military Lending Act Military Service Members Regulation Z

CFPB Announces Field Hearing on Arbitration

On February 23, 2015, the Consumer Financial Protection Bureau (CFPB) announced that it will hold a field hearing in Newark, New Jersey, on March 10, 2015, to discuss the topic of arbitration. We anticipate that the CFPB will...more

2/25/2015 - Arbitration CFPB Dodd-Frank

The CFPB 2015 Forecast: Continued Cloudiness, Thunderstorms Likely

This will be a busy year at the Consumer Financial Protection Bureau (CFPB), and that certainly means it will be a busy year for financial institutions as well. In addition to exercising its supervisory and enforcement...more

1/26/2015 - Automotive Loans Banking Sector CFPB Consumer Lenders Debt Collection ECOA Financial Institutions HMDA Integrated Disclosures Mortgage Lenders Mortgages Prepaid Payment Products Proposed Regulation Regulation C RESPA Supervision Truth in Lending Act (TILA) UDAAP

CFPB Weighs in on Department of Defense Military Lending Act Proposed Rule

On December 29, 2014, the Consumer Financial Protection Bureau (CFPB) released a report, entitled “The Extension of High-Cost Credit to Servicemembers and Their Families” (“Report”). According to the CFPB, the Report provides...more

1/2/2015 - CFPB Consumer Lenders Department of Defense (DOD) Lenders Military Lending Act Military Service Members

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