Oliver I. Ireland

Oliver I. Ireland

Morrison & Foerster LLP

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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

The Fed Revisits CCAR and Proposes CCAR Relief for Large Noncomplex Firms

One of the notable financial regulatory tools that resulted from the post-financial crisis prudential regulations is stress testing. The Board of Governors of the Federal Reserve System (the “Federal Reserve”) has the...more

9/29/2016 - CCAR Central Counterparties Consumer Protection Act Dividends Dodd-Frank Federal Reserve Financial Institutions G-SIB Nonbank Firms Reporting Requirements Stress Tests Threshold Requirements Transparency

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

Structured Thoughts: News for the financial services community, Volume 7, Issue 9

Updating Unregistered Structured Note Programs: How Frequently? - For some types of securities offering programs, we have “black letter law” that instructs issuers how frequently the program documentation should be...more

9/15/2016 - BaFin Bank Holding Company Brokerage Accounts Cease and Desist Orders Duty to Update Federal Reserve Financial Sector FINRA Fixed Income Investments Germany Income Tax Act Private Funds SEC Subsidiaries TLAC TRACE

H.R. 5983—Act as Introduced—Title I

U.S. Congressman Jeb Hensarling, Chairman of the House Financial Services Committee, has set the stage for the consideration of regulatory reform and burden reduction with the introduction of H.R. 5983, the “Financial Choice...more

9/13/2016 - Banking Sector Exemptions Financial Institutions Financial Services Committee Regulatory Reform Title I

Federal Banking Agencies Issue Recommendations as Part of Their Section 620 Report to Solidify the Safety and Soundness of the...

On September 8, 2016, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), the Federal Deposit Insurance Corporation (the “FDIC”) and the Office of the Comptroller of the Currency (the “OCC,” and...more

9/12/2016 - Bank Holding Company Act Dodd-Frank FDIC Federal Bank Regulatory Agencies Federal Reserve Financial Holding Company Financial Sector Hedging OCC Prudential Standards Risk Management Savings and Loan Companies Volcker Rule

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

Don’t Drain the River: How US Bank Resolution Reform Will Dry Liquidity

Well-meaning initiatives to end the era of US bailouts have also dried-up market liquidity. That could be almost as dangerous - Banks perform critical functions in our economy, one of which is maturity transformation....more

6/15/2016 - Bailout Banking Sector Banks Capital Requirements Dodd-Frank Financial Institutions Liquidity Coverage Ratio Volcker Rule

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

The Metaphysics Of Systemic Risk

On April 18, 2016, the Financial Stability Oversight Council again warned that asset managers present systemic risk to financial stability in five key areas: ..liquidity and redemptions; ..leverage; ..operational...more

5/16/2016 - Asset Management Dodd-Frank Financial Institutions Financial Stability Acts FSOC Risk Assessment

Bankers' poll: TLAC and the future of bank debt

To say bank bonds had a rocky start to 2016 would be an understatement. Over the first weeks of January, the market’s significant gains from last year were essentially wiped out, with European issuers hit particularly hard....more

5/3/2016 - Banking Sector Bonds BRRD China Debt Debt Market EU FSB Global Economy Investors Non-Marketable Debt Instruments TLAC

Is the End in Sight? FDIC Proposes the Net Stable Funding Ratio (“NSFR”): Liquidity Risk Measurement Standards and Disclosure...

On April 26, 2016, the Federal Deposit Insurance Corporation (the “FDIC”) proposed a rule (the “Proposed Rule”) that would implement a quantitative long-term liquidity requirement—the net stable funding ratio (“NSFR”)—for...more

4/28/2016 - Banking Regulators Banking Sector Derivatives Disclosure Requirements FDIC Liquidity Risk Management Rule Net Stable Funding Ratio (NSFR) Proposed Regulation

Possible Worlds Versus Probable Worlds - the Metaphysics of Systemic Risk: FSOC Revisits Asset Managers

On April 18, 2016, the Financial Stability Oversight Council (FSOC) again warned that asset managers present systemic risk to financial stability in five key areas: ..liquidity and redemptions; ..leverage;...more

4/27/2016 - Asset Management Dodd-Frank FSOC Mutual Funds SEC

New Executive Compensation Rule At-A-Glance

On April 21, 2016, the National Credit Union Administration approved a proposed rule on incentive compensation under Section 956 of the Dodd-Frank Act. The other appropriate Federal regulators, as defined in Section 956, are...more

4/26/2016 - Covered Entities Dodd-Frank ERISA Executive Compensation NCUA

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

Another Brick in the Wall: The Fed Reproposes Single-Counterparty Credit Limits for Large Banking Organizations

On March 4, 2016, the Board of Governors of the Federal Reserve System (the “Fed”) issued a Notice of Proposed Rulemaking (“NPRM”), inviting comment on reproposed rules (the “Reproposed Rules”) that would establish single...more

3/10/2016 - Bank Holding Company Banks Credit Dodd-Frank Federal Reserve Foreign Banks NPRM

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)

Too-big-to fail, RIP?

The latest set of prudential rules is the strongest sign yet that too-big-to-fail has seen its last days - Despite the comprehensive reforms put in place in the wake of the financial crisis by the landmark Dodd-Frank...more

2/23/2016 - Bailout Bank Holding Company Dodd-Frank FBOs TLAC Too Big to Fail

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

Bubble, Bubble Toil and Trouble: The Fed Breathes Life into the Countercyclical Capital Buffer

Widespread problems in the banking system are often associated with sharp declines in asset prices, or the economy more broadly. When these declines result in loan defaults, bank capital can erode, leading to more stringent...more

12/24/2015 - Banks Basel III Dodd-Frank FDIC Federal Reserve

TLAC, and Then Some… A Preliminary Assessment of the Federal Reserve Board’s NPR

On Friday, October 30, 2015, the Federal Reserve Board (“Board”) reaffirmed its commitment to both the bank holding company model and single point of entry resolution. In a departure from historical views of the purpose and...more

11/2/2015 - Bank Holding Company Banking Sector Comment Period Debt Disclosure Requirements Dodd-Frank FBOs Federal Reserve G-SIB Holding Companies NPRM Proposed Regulation Public Disclosure Receivership Structured Financial Products Subsidiaries Too Big to Fail Unsecured Debt

LCR – The Fed Takes Tentative Step to Expand HQLAs

When the Office of the Comptroller of the Currency (the “OCC”), the Board of Governors of the Federal Reserve System (the “Board”) and the Federal Deposit Insurance Corporation (the “FDIC”) finalized the Liquidity Coverage...more

6/2/2015 - Bank Holding Company Banks FDIC Federal Reserve Financial Institutions HQLA Liquidity Coverage Ratio Municipal Securities Issuers OCC

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