Matthew W. Janiga

Matthew W. Janiga

Morrison & Foerster LLP

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CFPB Announces Potential Model Packaging Disclosures for GPR Prepaid Cards

On March 18, 2014, the Consumer Financial Protection Bureau (CFPB) continued its long march toward regulating general-purpose reloadable (GPR) prepaid cards by releasing test model disclosures for prepaid card packaging that...more

3/24/2014 - CFPB OMB Prepaid Payment Products

Socially Aware - Volume 5, Issue 1 - January/February 2014

In This Issue: FFIEC Issues Final Guidance on Social Media Usage by Financial Institutions; Uncovering a Line in the Sand: Employee Social Media Use and the NLRA; Website Operators Await Final Guidance Regarding...more

2/3/2014 - Disclosure Do Not Track FFIEC First Amendment Mobile Apps NLRA NLRB Privacy Policy Social Media

FFIEC Issues Final Guidance on Social Media Usage by Financial Institutions

On December 11, 2013, the Federal Financial Institutions Examination Council (FFIEC) issued final guidance for financial institutions relating to their use of social media (the “Guidance”). With its release, the FFIEC adopts...more

1/9/2014 - Audits Banks Compliance FFIEC Social Media

CFPB Increases Penalty Fee Safe Harbor Amounts for Card Issuers

In yesterday’s Federal Register, the Consumer Financial Protection Bureau (“CFPB”) published an amendment to the safe harbor thresholds for credit card penalty fees found in Section 1026.52(b)(1)(ii) of Regulation Z to...more

12/18/2013 - CFPB Consumer Price Index Regulation Z Safe Harbors

CFPB Brings First Enforcement Action Involving Deferred Interest Products, Imposes Novel and Burdensome Application Requirements...

Yesterday, the Consumer Financial Protection Bureau (“CFPB”) announced a consent order with GE Capital Retail Bank and its subsidiary CareCredit (collectively “CareCredit”) related to what the CFPB alleges were unfair and...more

12/12/2013 - Applications CARD Act CareCredit CFPB Consent Order Credit Cards Deferred Interest Products Disclosure Requirements Enforcement Actions GE Capital Retail Bank Remediation

Financial Services Report - Quarterly News, Winter 2013

Editor’s Note - Stuff didn’t happen this quarter. Lots of it. The federal government didn’t happen for two weeks in October, which caused some to celebrate and others to wring their hands and clamor for a strong,...more

12/11/2013 - Affordable Care Act CARD Act HAMP Healthcare HMDA HOLA HUD

CFPB Signals Additional Concerns about Consumer Credit Card Market with Report on CARD Act

Yesterday, the Consumer Financial Protection Bureau (“CFPB”) released the “CARD Act Report,” a report summarizing the CFPB’s views on the impact of the Credit Card Accountability Responsibility and Disclosure Act of 2009...more

10/3/2013 - CARD Act CFPB Credit Cards Disclosure Requirements Fees

Financial Services Report - Quarterly News, Fall 2013

In This Issue: Beltway Report; Bureau Report; Privacy Report; Mobile Payments Report; Mortgage Report; Operations Report; Preemption Report; Arbitration Report; and TCPA Report. Excerpt from Beltway Report:...more

9/17/2013 - Arbitration EFTA Federal Reserve Mobile Payments Mortgages Preemption Privacy Policy TCPA

Senators Request CFPB Issue Guidance and Rulemakings, Bring Enforcement Actions Relating to Payroll Card Programs

Last week, 16 Democratic Senators sent a letter on regulation of payroll cards to Consumer Financial Protection Bureau (“CFPB”) Director Richard Cordray and Department of Labor (“DOL”) Acting Secretary Seth Harris. The letter...more

7/19/2013 - CFPB DOL EFTA Enforcement Actions Minimum Wage Payroll Cards

CFPB Fair Lending Guidance for Indirect Auto Lenders—It’s Not Just About Cars

Several weeks ago, the Consumer Financial Protection Bureau (“CFPB”) issued a fair lending guidance bulletin (“Bulletin”) directed at financial institutions that make indirect automobile loans. While the Bulletin thus far has...more

6/5/2013 - Automotive Industry CFPB Compliance Dodd-Frank DOJ ECOA Enforcement Fair Lending HMDA Nissan Regulation B Rulemaking Process

CFPB Uses Novel Interpretation, Increases Compliance Burden for Gift Card Issuers Through its First Preemption Determination

On April 19, 2013, the Consumer Financial Protection Bureau (“CFPB”) announced it was making a determination to preempt a provision of Tennessee unclaimed property law that it deemed inconsistent with the federal Electronic...more

4/24/2013 - CFPB Disclosure Requirements EFTA Gift-Cards Preemption Regulation E Unclaimed Property

FTC Releases Report on Improving Consumer Protections in Mobile Payments; Recommends Financial, Privacy and Data Security...

On March 8, 2013 the Federal Trade Commission (“FTC”) released a Report on mobile payments that serves to follow up on the FTC’s April 2012 workshop on mobile payments, as well as to lay the groundwork for the application of...more

3/14/2013 - Data Protection FTC Mobile Devices Mobile Payments

CFPB Warning and Bulletin for Nationwide Specialty CRAs

The Consumer Financial Protection Bureau (“CFPB”) has sent warning letters to several nationwide specialty consumer reporting agencies (“CRAs”), notifying the CRAs that the CFPB believes that the CRAs are not complying with...more

12/3/2012 - CFPB Credit Reporting Agencies Credit Reports FCRA

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