Rick Fischer

Rick Fischer

Morrison & Foerster LLP

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CFPB to Assume a Larger Role in Virtual Currency Initiatives

On June 26, 2014, the U.S. Government Accountability Office (“GAO”) released a report, entitled “Virtual Currencies: Emerging Regulatory, Law Enforcement, and Consumer Protection Challenges.” The report, delivered earlier to...more

7/8/2014 - CFPB DHS DOJ GAO Information Reports IRS Law Enforcement Legislative Committees Popular Property Tax Virtual Currency

CFPB Further Delays Prepaid Proposed Rule

Industry anticipation continues to grow as the Consumer Financial Protection Bureau (CFPB) announced that its general-purpose reloadable (GPR) prepaid card proposal will now be issued by the end of the summer. Although this...more

6/30/2014 - CFPB Disclosure Legislative Agendas Prepaid Payment Products Proposed Regulation Rulemaking Process

CFPB Issues a Request for Information Related to Mobile Financial Services

Yesterday, the Consumer Financial Protection Bureau (“CFPB”) released a request for information (“RFI”) concerning the use of mobile financial services, specifically among unbanked and underbanked consumers. The RFI was...more

6/13/2014 - CFPB Data Protection Mobile Apps Mobile Banking Request For Information

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

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

OCC Issues New Third-Party Risk Management Guidance

On October 30, 2013, the Office of the Comptroller of the Currency (OCC) issued new guidance on risks presented by third-party relationships, entitled “Third-Party Relationships: Risk Management Guidance” (“2013 Bulletin”)....more

11/22/2013 - Banks Board of Directors Due Diligence OCC Reporting Requirements Risk Management Third-Party Risk

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

The Consumer Financial Protection Bureau: Measuring the Progress of a New Agency

In This Issue: Executive Summary; Introduction; Focus of Consumer Protection Task Force; History of the CFPB; Rule-Making; Examinations and Data; Consumer Relations; The Scope of CFPB Authority; Transparency; CFPB...more

9/24/2013 - CFPB Funding Industry Examinations Transparency

Inter-Governmental Task Force Recommends Extending Anti-Money Laundering Measures to Telecoms, Software Companies and Other...

The Financial Action Task Force (“FATF”) recently released a white paper entitled “Guidance for a Risk Based-Approach: Prepaid Cards, Mobile Payments and Internet-based Payment Services” (“Guidance”). The Guidance contains...more

7/23/2013 - Anti-Money Laundering Financial Action Task Force Mobile Payments Risk Assessment Risk Management Telecommunications

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

Bitcoin Receives Cease and Desist Order Evidencing Increased Regulatory Scrutiny of Virtual Currency

On May 30, 2013, the California Department of Financial Institutions (“CADFI”) issued a cease and desist letter to Bitcoin Foundation, a not-for-profit organization established to standardize, protect, and promote the use and...more

7/19/2013 - Bitcoins Business Assets Cease and Desist Financial Actvities FinCEN Virtual Currency

Mobile Apps Bill Introduced in the House of Representatives

Lawmakers in Washington, D.C., continue to show interest in understanding and developing regulatory proposals relating to mobile apps. The interest appears to be driven, at least in part, by policymakers’ concerns about...more

6/6/2013 - Data Collection Data Protection FTC Mobile Apps Mobile Payments Notice Requirements Personally Identifiable Information Proposed Legislation Safe Harbors

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

Financial Services Report - Spring 2013

Editor’s Note - This is a dignified law firm newsletter, not like the “Brand X” versions. You won’t find pandering, attention-grabbing stories about Justin Bieber, Kim Kardashian, Ashton Kutcher, Prince William, or...more

3/13/2013 - Arbitration Barack Obama CFPB China Credit Reports Cybersecurity Data Protection Debt Collection Dodd-Frank Dukes v Wal-Mart FDCPA FDIA FDIC Federal Reserve FHA Foreclosure FTC Mobile Apps Recess Appointments Richard Cordray Social Media Telemarketing

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

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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