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D.C. Circuit Rebukes CFPB in Civil Investigative Demand Enforcement Decision

On April 21, the U.S. Court of Appeals for the District of Columbia Circuit issued an opinion in CFPB v. Accrediting Council for Independent Colleges & Schools, affirming a decision by the D.C. district court to deny...more

FinCEN Proposes Fifth BSA Pillar

On July 30, 2014, the Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking (the Proposed Rule) to clarify and strengthen customer due diligence (CDD) requirements as a fifth pillar under the...more

One Big Misunderstanding: FDIC Clarifies that Caution on Higher-Risk Activity Is Not a Prohibition on Third-Party Payment...

On July 28, 2014, in response to growing pressure from Congress and the banking industry, the Federal Deposit Insurance Corporation (FDIC) issued Financial Institution Letter 41-2014 to clarify its supervisory approach to...more

FIRREA: The New Weapon of Choice for Federal Prosecutors [Video]

In 2013, the Department of Justice Civil Division has brought several actions claiming violations of The Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (FIRREA). Pepper Hamilton recently hosted a webinar...more

Will New U.S. Court Of Appeals Decision On ‘Recess Appointments’ Stay Dodd-Frank Powers Granted To CFPB And Vacate Certain...

Holding that recess appointments authorized by the Recess Appointments Clause of the U.S. Constitution are limited to “intersession recesses” – “the period between sessions of the Senate when the Senate is by definition not...more

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