Oliver I. Ireland

Oliver I. Ireland

Morrison & Foerster LLP

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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

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)

Bureau Tells Banks to Offer Overdraft-Free Accounts, Sends Warning on Reporting

On February 3, 2016, the Consumer Financial Protection Bureau (CFPB or “Bureau”) announced a series of steps designed to improve consumer access to checking accounts by (a) encouraging banks and credit unions to make...more

2/4/2016 - Banking Sector CFPB Checking Accounts Consumer Reporting Agencies Deposit Accounts Overdraft Fees

OCC Takes a Page from the CFPB’s Playbook on Overdraft Programs

On February 11, 2015, the Office of the Comptroller of the Currency (“OCC”) issued an “updated” installment to the Comptroller’s Handbook in a new booklet entitled “Deposit-Related Consumer Credit.” In doing so, the OCC stole...more

2/13/2015 - Banks CFPB Financial Institutions Letter of Credit OCC Overdraft Fees

CFPB Complaints Database Expands to Include Prepaid Cards and Nonbank Products

On July 21, 2014, the Consumer Financial Protection Bureau (“CFPB”) announced that it has further expanded its Consumer Complaint Database (“Database”) to include additional types of financial products. Specifically, the CFPB...more

7/23/2014 - CFPB Consumer Complaint System Credit Repair Services Debt Settlement Services Prepaid Payment Products

Bureau Proposes Sharing Consumer Narratives in Complaints Database

On July 17, 2014, the Consumer Financial Protection Bureau (“CFPB”) held a field hearing in El Paso, Texas to announce a new policy proposal (“Proposal”) that would expand the Consumer Complaint Database (“Database”) to allow...more

7/22/2014 - CFPB Consumer Complaint System

CFPB Proposes Definition of Larger Participants for the International Money Transfer Market

On January 23, 2014, the Consumer Financial Protection Bureau (“CFPB”) issued a proposed rule that would define which nonbank covered persons would be designated “larger participants” for purposes of the international money...more

1/27/2014 - CFPB Debt Collection Dodd-Frank Electronic Fund Transfer Act Larger Participant Money Transfer Nonbank Firms Regulation E Student Loans

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 CFPB Consent Order Credit Cards Deferred Interest Products Disclosure Requirements Enforcement Actions GE Capital Retail Bank Remediation

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

D.C. Circuit Hands the CFPB a Setback?

At the end of last week, the U.S. Court of Appeals for the District of Columbia Circuit issued its decision in Noel Canning v. National Labor Relations Board, holding that President Obama’s recess appointments to the National...more

1/30/2013 - Barack Obama Canning v NLRB CFPB NLRB Political Appointments Pro Forma Sessions Recess Appointments Richard Cordray

Dodd-Frank Implementation: Navigating the Road Ahead

Table of Contents: Introduction; Financial Stability Reform; Resolution Planning; Agencies and Agency Oversight Reform; Securitization Reform; Derivatives Regulation; Investor Protection Reform; Credit Rating Agency...more

12/29/2012 - Capital Requirements CFPB Corporate Governance Credit Ratings Derivatives Disclosure Requirements Dodd-Frank Financial Stability Acts Foreign Banks Mortgage Loan Originators Mortgages Securitization Servicing Policies Volcker Rule

Financial Services Report -- Winter 2012

In This Issue: Bureau Report; Operations Report; Beltway Report; Arbitration Report; Mortgage Report; Privacy Report; Preemption Report; and Plastics Report. Excerpt from the Bureau Report: World’s Most...more

12/18/2012 - American Express CFPB Chase Bank Cybersecurity Debt Collection Dodd-Frank FDIC FTC Google Mobile Apps MySpace Project Catalyst Stress Tests Truth in Lending Act (TILA)

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