On October 5, 2017, the Consumer Financial Protection Bureau released its final rule for short-term loans. The nearly 1,700 page rule appears to follow the proposed short-term lending rule with several notable changes. Most...more
On August 4, 2017, the Consumer Financial Protection Bureau (CFPB) released four “prototype” model overdraft disclosure forms styled under its “Know Before You Owe” initiatives with a press release. The CFPB said the forms...more
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
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
3/16/2017
/ Banking Sector ,
CARD Act ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Cards ,
Creditors ,
Debt Collection ,
Deferred Interest Products ,
Innovation ,
Online Banking ,
Request For Information ,
Subprime Loans
On March 9, 2017, the Consumer Financial Protection Bureau (Bureau or CFPB) announced in a blog post a proposal to delay the effective date of the final rule on prepaid accounts (Final Rule) for six months to April 1, 2018....more
The Consumer Financial Protection Bureau issued its final rule to amend provisions of Regulation E and Regulation Z to further regulate prepaid card products, or “prepaid accounts.” As discussed below, the rule generally...more
11/3/2016
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Cards ,
Disclosure Requirements ,
Dispute Resolution ,
Final Rules ,
Financial Institutions ,
Overdraft Fees ,
Prepaid Payment Products ,
Regulation E ,
Regulation Z
On October 5, 2016, the Consumer Financial Protection Bureau (“CFPB”) issued its long-awaited final rule to further regulate prepaid card products, or “prepaid accounts” (the “Final Rule” or “Rule”). The Final Rule follows...more
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
The comment period to the CFPB’s Notice of Proposed Rulemaking for Prepaid Accounts (the “Proposed Rule”) closed in March, but 43 Members of Congress (42 Republicans and 1 Democrat) recently sent a letter to Director Cordray...more
10/8/2015
/ Apple Pay ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Debit and Credit Card Transactions ,
Disclosure Requirements ,
Overdraft Fees ,
p2p ,
Prepaid Payment Products ,
Product Packaging ,
Proposed Regulation ,
Regulation Z ,
Visa Inc
Where do we go from here? As we mark another milestone in regulatory reform with the fourth anniversary of the enactment of the Dodd-Frank Act, it strikes us that although most studies required to be undertaken by the Act...more
8/6/2015
/ Accredited Investors ,
AIF ,
Alternative Investment Fund Managers Directive (AIFMD) ,
Bank Recovery and Resolution Directive (BRRD) ,
Capital Rules ,
CFTC ,
Compliance ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Reporting Agencies ,
Covered Banking Entity ,
Covered Funds ,
Credit Cards ,
Cross-Border Transactions ,
Debt Collection ,
Derivatives ,
Dodd-Frank ,
ECOA ,
EMIR ,
EU ,
European Securities and Markets Authority (ESMA) ,
Executive Compensation ,
Exemptions ,
Fair Credit Reporting Act (FCRA) ,
Fair Lending ,
FDCPA ,
FDIC ,
Federal Reserve ,
Fiduciary Duty ,
Final Rules ,
Financial Regulatory Reform ,
Financial Transaction Tax ,
Foreign Banks ,
FSOC ,
HMDA ,
HOEPA ,
Incentive Compensation ,
Investment Company Act of 1940 ,
IOSCO ,
Liquidity Risk Management Rule ,
MiFID II ,
Mortgage Servicing Rules ,
NRSRO ,
OCC ,
Privacy Notice Rule ,
Proprietary Trading ,
Prudential Standards ,
Remittance Transfer Rule ,
Reporting Requirements ,
Risk Management ,
Security-Based Swaps ,
Shadow Banking ,
SIFIs ,
Stand-Alone SBSDs ,
Swap Execution Facilities ,
TILA-RESPA Integrated Disclosure Rule (TRID) ,
Transparency ,
Truth in Lending Act (TILA) ,
UCITS ,
UDAAP ,
Volcker Rule
On May 12, 2015, the Consumer Financial Protection Bureau (the “CFPB”) filed proposed consent orders in federal courts that would settle allegations that two wireless carriers unfairly permitted their customers to be charged...more
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
On March 19, 2015, the Consumer Financial Protection Bureau (“CFPB”) published a notice and request for information (“2015 RFI”) regarding the impact of the Credit Card Accountability Responsibility and Disclosure Act of 2009...more
On December 17, 2014, the Consumer Financial Protection Bureau (“CFPB”) announced that it had filed a lawsuit against a telecommunications carrier, alleging that the carrier was allowing third-party merchants to place...more
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
Today, the Consumer Financial Protection Bureau (“CFPB”) issued its long-awaited proposed rule to further regulate prepaid card products (the “Proposed Rule”). The Proposed Rule was the topic of discussion at a field hearing...more
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
/ Consumer Financial Protection Bureau (CFPB) ,
Department of Homeland Security (DHS) ,
Department of Justice (DOJ) ,
GAO ,
Information Reports ,
IRS ,
Law Enforcement ,
Legislative Committees ,
Popular ,
Property Tax ,
Virtual Currency
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
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
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
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
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
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
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
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