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Federal Agencies Announce Ramp-Up of Redlining Enforcement

The Department of Justice (DOJ) joined other federal agencies in announcing an increased focus on fair lending issues. On October 22, 2021, DOJ announced a new initiative to crack down on “modern-day” redlining. DOJ is...more

Will The True Lender Please Stand? – OCC Proposes “True Lender” Bright-Line Rule

On July 20, 2020, the Office of the Comptroller of the Currency (OCC) issued a notice of proposed rulemaking that would establish when national banks or federal savings associations (collectively, banks) are the “true lender”...more

NY Governor Cuomo Orders Power To Require Waiver Of Deposit Fees During COVID-19 Emergency

As Congress scrambles to pass a stimulus package to alleviate financial strain due to the COVID-19 pandemic, federal regulators and some states are directing financial institutions to provide immediate relief. So far,...more

CFPB Initiates Fourth Review of the Consumer Credit Card Market

On January 31, 2019, the Consumer Financial Protection Bureau (CFPB or Bureau) published a Request for Information (2019 RFI) regarding the consumer credit card market. In accordance with Section 502(a) of the Credit Card...more

OCC Releases Semiannual Risk Perspective: Fintech is Risky?

On July 7, 2017, the Office of the Comptroller of the Currency (“OCC”) released its Semiannual Risk Perspective report (the “Report”) identifying the risks faced by national banks and federal savings associations in the ...more

CFPB Initiates Third CARD Act Review

On March 10, 2017, the Consumer Financial Protection Bureau (CFPB or Bureau) published a Request for Information (2017 RFI) regarding the consumer credit card market. In accordance with Section 502(a) of the Credit Card...more

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

CFPB Finalizes Rule Suspending Quarterly Submission of Credit Card Agreements

On April 15, 2015, the Consumer Financial Protection Bureau (“CFPB”) announced a final rule (“Final Rule”) that suspends for one year the requirement under the Truth in Lending Act and implemented by Regulation Z that credit...more

Overview of the CFPB Prepaid Account Proposed Rule

On November 13, 2014, the Consumer Financial Protection Bureau (“CFPB”) issued a proposed rule to regulate prepaid accounts (the “Proposed Rule”). The Proposed Rule follows the CFPB’s May 2012 advance notice of proposed...more

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