Robert H. Ledig

Robert H. Ledig

Dechert LLP

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The New Future of US Banking and Financial Services Regulation

The presidential election has opened the possibility of significant changes to the Dodd-Frank Act regime that has been implemented over the last six years. It remains to be seen what plans the incoming administration will...more

11/30/2016 - Banks CFPB Dodd-Frank Donald Trump FDIC Financial Institutions FSOC Glass-Steagall Act Liquidation Presidential Elections Shadow Banking Too Big to Fail Trump Administration Volcker Rule

Court of Appeals Says CFPB Is Unconstitutional; Rejects Agency Effort to Apply New Interpretation of Law Retroactively

The courts are now reacting to what some view as regulatory overreach flowing from U.S. laws enacted in the wake of the financial crisis. The most recent example is the October 11, 2016 decision of the U.S. Court of Appeals...more

10/15/2016 - Anti-Kickback Statute Appeals CFPB Constitutional Challenges Director Removal Dodd-Frank Due Process Government Agencies Mortgage Lenders PHH Corp. v CFPB Removal At-Will Removal For-Cause RESPA Reversal Separation of Powers Single Director Statutory Interpretation

Implications of the 2016 Election for Banks, Systemically Important Financial Institutions and Their Investors

Campaign promises rarely turn into specific actions, but when they do, they are necessarily impacted by the dynamics of the legislative process. History suggests, however, that the policies of candidates can be a predictor of...more

10/12/2016 - Acquisitions Banks CFPB Dodd-Frank Donald Trump FDIC Federal Reserve Financial Regulatory Reform Financial Sector FSOC Hillary Clinton Industry Consolidation Liquidity Mergers Mortgages OCC Policy Terms Presidential Elections Receivership SIFIs Too Big to Fail Volcker Rule

CFPB Outlines New Proposals For Third Party Consumer Debt Collection

The Consumer Financial Protection Bureau (CFPB) in the U.S. published an outline of proposals on July 28, 2016 to govern consumer debt collection by debt collectors including third-party collection agencies, debt buyers,...more

9/2/2016 - Burden of Proof CFPB Debt Buyers Debt Collection Debt Collectors Dispute Resolution Dodd-Frank Evidence FDCPA Loan Servicing Mortgage Loan Servicing Standards Native Language Proposed Rules Statute of Limitations Third-Party Service Provider Time-Barred Debt

BNA INSIGHTS: Enforcement Actions Decline But Fines Hit Historic Highs in 2014

During 2014, the number of enforcement actions brought by federal banking agencies1 continued a downward trend that began in 2011. Federal banking agencies issued 661 formal enforcement actions, representing more than a 55...more

6/24/2015 - Banking Sector CFPB Choke Point Civil Monetary Penalty Corporate Fines DOJ Enforcement Actions Enforcement Statistics FDIC Financial Institutions FIRREA Foreign Currency Mortgage-Backed Securities RMBS Strategic Enforcement Plan

BNA's Banking Report: Enforcement 2013: Enforcement Actions Continue Three-Year Decline; DOJ Emerges as Major Player

Overall Trends & Outlook - From an enforcement standpoint, 2013 was another historic year in a number of important ways beyond the sheer number of cases, which were again significant. Federal banking agencies1 issued...more

5/29/2014 - Anti-Money Laundering Bank Secrecy Act Banks CFPB DOJ ECOA Enforcement Enforcement Actions FIRREA Risk Management

Impact of Ability-to-Repay and Qualified Mortgage Rules on Residential Mortgage Loan Purchasers, RMBS Participants and Mortgage...

Loan originators, their advisors and service providers are moving rapidly to achieve compliance by January 10, 2014 with the Consumer Financial Protection Bureau’s (“Bureau’s”) new rule, which generally imposes an affirmative...more

10/4/2013 - Ability-to-Repay CFPB Dodd-Frank Investors Mortgages Qualified Mortgage Rule

U.S. Consumer Financial Protection Bureau Acts to Expand Its Authority Over Nonbank Consumer Financial Services Companies

The Consumer Financial Protection Bureau (“Bureau”), pursuant to its authority to extend its supervision to persons that offer or provide any consumer financial product or service that poses a risk to consumers, has adopted a...more

8/15/2013 - CFPB Compliance Dodd-Frank Final Rules Financial Products Financial Regulatory Reform Nonbank Firms

American Bankers Association Real Estate Lending Conference - Qualified Mortgages: A Sea Change For Mortgage Lenders

In This Presentation: - The Qualified Mortgage (QM) Rule - Small Creditor QM Proposal - The Ability-to-Repay (ATR) Rule: What It Says and What It Means - Liability for Failure to Comply with the ATR and QM...more

4/16/2013 - Ability-to-Repay CFPB Disparate Impact Fair Lending HUD Lenders Loans Mortgages Qualified Mortgage Rule Safe Harbors Underwriting

2012 Bank Enforcement Actions Still High, But Significantly Lower Than 2010-11

Originally published in BNA’s Banking Report, 100 BBR 617 on 04/02/2013. Overall Trends & Outlook - In 2012, the federal banking agencies, including the Federal Deposit Insurance Corporation (‘‘FDIC’’), Office...more

4/4/2013 - Anti-Money Laundering CFPB Enforcement Actions Fair Lending FCRA FDIC FinCEN Mortgage Reform OCC OFAC Unfair or Deceptive Trade Practices

U.S. Consumer Financial Protection Bureau Seeks Comments to Proposed Amendments to the Ability-to-Repay Requirements and Qualified...

The U.S. Consumer Financial Protection Bureau (the “Bureau”) has released a proposal (the "Proposal") to amend the Bureau's recently issued final rules (the “Rules”) on the definition of a qualified mortgage (“QM”) and the...more

2/15/2013 - Ability-to-Repay CFPB Exemptions Mortgages Qualified Mortgage Rule Safe Harbors

U.S. Consumer Financial Protection Bureau Issues Rules on Qualified Mortgages and Ability to Repay

Congress in the Dodd-Frank Act responded to concerns about the quality of mortgage loans by establishing incentives for lenders to seek to ensure that borrowers had the ability to repay mortgage loans made to them. In...more

1/16/2013 - Ability-to-Repay Borrowers CFPB Damages Dodd-Frank Foreclosure Lenders Loans Mortgages Penalties Qualified Mortgage Rule Rebuttable Presumptions Safe Harbors Truth in Lending Act (TILA)

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