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CSBS Releases Cybersecurity Programs to Help Nonbank Financial Services Institutions Improve Cybersecurity Posture

On August 9, 2022, the Conference of State Bank Supervisors (CSBS) released two cybersecurity tools for nonbank financial services institutions to help prepare for state cybersecurity exams and, ultimately, improve...more

California Settlement Offers Reminder that Buy Now Pay Later Participants are Subject to California Financing Law

In August 2022, the California Department of Financial Protection and Innovation (“Department” or “DFPI”) entered into a consent order with a company offering point of sale financing products that the DFPI deemed to be buy...more

Maryland Issues Executive Order Restricting Foreclosure Actions and Prohibiting Evictions During COVID-19 Emergency

A&B ABstract: Maryland’s Governor has issued an Executive Order providing that until the COVID-19 state of emergency is terminated: (1) foreclosure sales will only be valid if the servicer had notified the borrower of their...more

FTC Seeks Comment on Proposed Changes to FCRA Rules for Motor Vehicle Dealers

A&B ABstract: The FTC is seeking public comment on proposed changes to five FCRA rules aimed at clarifying that these rules, as promulgated by the FTC, apply only to motor vehicle dealers, as equivalent rules promulgated by...more

New York Laws Require Forbearance for Private Mortgage Loans During COVID Emergency

A&B ABstract - On June 17, 2020, New York Governor Andrew Cuomo signed into law two measures, effective immediately, providing for mortgage forbearances for privately backed residential mortgage loans during the COVID-19...more

Key Provisions of the CARES Act Affecting Mortgage Servicers

A&B ABstract: In response to COVID-19, on Friday March 28, 2020, President Trump signed into law the “Coronavirus Aid, Relief, and Economic Security Act” (the “CARES Act”).  This is a monumental $2 trillion stimulus...more

CFPB Issues Policy Statement on Dodd-Frank “Abusiveness” Standard, But Important Uncertainties Remain

A&B ABstract: The Consumer Financial Protection Bureau (“CFPB” or the “Bureau”) issued a Policy Statement to provide a framework for how it intends to apply the Dodd-Frank Act’s “abusiveness” standard going forward in its...more

Puerto Rico Office of the Commissioner of Financial Institutions Announces Mandatory Mortgage Servicer Reporting in Response to...

A&B Abstract: In the wake of the recent earthquakes in Puerto Rico, the Puerto Rico Office of the Commissioner of Financial Institutions (“OCFI”) released Circular Letter No. CFI-2020-01 (the “Circular Letter”). ...more

New York Overhauls Mortgage Loan Servicer Business Conduct Regulations

New York’s amended mortgage loan servicer regulations are a substantial departure from previous versions and could go beyond federal rules. Our Financial Services & Products Group delves into technicalities and ramifications...more

CFPB Updates Financial Institution Guidance on Elder Financial Exploitation

A&B ABstract: In July 2019, the Consumer Financial Protection Bureau (“CFPB”) issued an update to its 2016 Advisory and Recommendations for Financial Institutions on Preventing and Responding to Elder Financial...more

Supreme Court to Decide CFPB’s Constitutionality

A&B ABstract: On October 18, 2019, the Supreme Court granted certiorari in Seila Law v. CFPB to decide the constitutionality of the Consumer Financial Protection Bureau’s leadership structure....more

A Closer Look at the CFPB’s Proposed Debt Collection Rules – Part Two: Communications

A&B Abstract: This blog post is part two of a five-part series examining the Consumer Financial Protection Bureau’s (the “CFPB” or “Bureau”) proposed rule amending Regulation F (the “Proposed Rule”), which implements the...more

CFPB Seeks to Expand Its Dominion Over Consumer Lending with Strict Proposed Rules

On June 2, 2016, the Consumer Financial Protection Bureau (CFPB) released a long-anticipated proposal pursuant to its authority under the Dodd-Frank Wall Street Reform and Consumer Protection Act to regulate the provision and...more

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