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Treasury Releases White Paper on Online Marketplace Lending

The U.S. Treasury Department has released a white paper addressing the online marketplace lending industry. Based in part on the responses to Treasury's July 2015 Request for Information (RFI), the white paper offers a broad...more

Top 10 Financial Institution Considerations for 2016: #10 – Fair Lending

In our initial article announcing our top 10 considerations for financial institutions in 2016, our tenth and final consideration was fair lending risk, which seems to be perpetually on the radar of financial institutions...more

Top 10 Financial Institution Considerations for 2016: #9 – Truth in Lending Act/Real Estate Settlement Procedures Act Integrated...

In our initial article announcing our top 10 considerations for financial institutions in 2016, our ninth consideration was the new Truth in Lending Act/Real Estate Settlement Procedures Act Integrated Disclosure (TRID)...more

Bridging the Week - May 2016 #2

FiNCEN Finalizes Rules Requiring Banks, Broker-Dealers, FCMs, Mutual Funds and IBs to Help Verify Beneficial Owners of Certain Accounts: The Financial Crimes Enforcement Network finalized rules requiring banks,...more

CFPB’s Proposal Marks Government’s Latest - and Largest - Step Regulating Arbitration Clauses

Last week at a field hearing in Albuquerque, New Mexico, the Consumer Financial Protection Bureau (CFPB) announced a proposed rule that would prohibit providers of certain consumer financial products and services from...more

Top 10 Financial Institution Considerations for 2016: #6 – Vendor Risk Management

In our initial article announcing our top 10 considerations for financial institutions in 2016, our sixth consideration was vendor risk management in 2016. Third party (vendor) risk management has consistently been among the...more

OCC Introduces Framework for Responsible Innovation

On March 31, 2016 the Office of the Comptroller of the Currency (OCC) issued a white paper setting forth its vision of responsible innovation, and signaling its increasing involvement in the financial technology (Fintech)...more

CFPB hires Assistant Director for Office of Small Business Lending Markets; announces other senior leadership additions

Earlier this week, the CFPB announced the addition of several new members to its senior leadership team. The announcement included the news that the CFPB has filled the position of Assistant Director for the Office of...more

California Releases Marketplace Lending Data

The California Department of Business Oversight (DBO) has issued a summary report of aggregate data provided by the companies that responded to the DBO's online survey sent to 14 marketplace lenders engaged in online consumer...more

Asset Finance & Leasing Newsletter

New GAP Insurance Rules - The FCA published new rules in June governing the sale of addon Guaranteed Asset Protection (GAP) insurance. The rules came into force on 1 September 2015 and apply to commercial customers as well...more

Director Cordray defends CFPB positions in appearance before Senate Banking Committee; comments on small business lending and...

Much of Director Cordray’s testimony in his appearance before the Senate Banking Committee yesterday consisted of his predictable defense of various CFPB positions. While the hearing was much less contentious than last...more

Too Small to Succeed or Ownership Structure to Thrive?

Two recent federal banking agency reports show very different pictures of the banking environment for community banks. In “Too Small to Succeed? – Community Banks in a New Regulatory Environment,” the Federal Reserve Bank of...more

What You Need to Know About the CFPB's Priorities for 2016 and 2017

The CFPB recently announced its policy priorities for the next two years. There are not too many surprises, since the CFPB has been targeting most of these areas in recent months and years. Here's what the Bureau is planning,...more

The Battle Over Fiduciary Status for Brokers Giving Retirement Advice Wages On

The battle over the DOL’s efforts to implement a new law that will impose a fiduciary standard on anyone giving retirement advice continues with some now questioning whether critics of the law really believe its effects will...more

Federal Reserve Set to Update Regulation Z to Add CFPB Rules

On February 19, the Federal Reserve noticed an information collection regarding recent changes to Regulation Z. The Notice (81 Fed. Reg. 8492) explains that the Federal Reserve is planning to update Regulation Z to include a...more

CFTC Intermediaries to Adopt and Implement Cybersecurity Programs by March 1, 2016

Commencing March 1, 2016, all commodity pool operators, commodity trading advisors, futures commission merchants, retail foreign exchange dealers, investment brokers, major swap participants and swap dealers that are National...more

CFPB policy priorities confirm rulemaking plans, interest in small business lending

In conjunction with yesterday’s meeting of the CFPB’s Consumer Advisory Board, which included a session on the CFPB’s strategic outlook, the CFPB issued its “near-term priority goals where we hope to make substantial progress...more

FDIC & Cyber: Words of Warning to Financial Institutions and their Boards

Financial institutions sit atop a wealth of personal information – not to mention money. In an interconnected world in which sensitive customer information is stored on servers and in the cloud – and online and mobile...more

FDIC "Framework for Cybersecurity" Highlights How Financial Institution Information Security Programs Can Better Respond to...

In February, 2016, the Division of Risk Management Supervision of the Federal Deposit Insurance Corporation (“FDIC”) published “A Framework for Cybersecurity.” The article provides a good “sanity check” for financial...more

Financial Markets Disputes and Regulatory Update - Winter 2015/Spring 2016

In this edition of our Financial Markets Disputes and Regulatory Update, we have considered the key financial markets cases and banking-related regulatory action from the second half of 2015, and distilled them into a list of...more

In Case You Missed It: Launch Links - Week of January 31, 2016

Some interesting links we found across the web this week: The State of Venture Capital - How much VC money is out there, and where is it coming from? Click through to the full presentation for a detailed...more

Raising the Stakes for AML Compliance Officers: Court Refuses to Rule Out Potential Liability for Role in Employer's BSA...

Why it matters - A federal court judge in Minnesota has rejected the motion of a former chief compliance officer to dismiss the U.S. government's claim that he is liable under the federal Bank Secrecy Act for his...more

Year in Review: Legislation and Guidance for Financial Institutions in 2015

Financial institutions in Canada witnessed yet another year of significant growth in legislation and regulatory guidance impacting their operations, while the financial marketplace is continuing to adapt to the impact of...more

Online Marketplace Lending on Review by California Regulator

Why it matters - Demonstrating the continuing regulatory interest in online lenders, the California Department of Business Oversight (DBO) announced an inquiry into the marketplace lending industry. While the agency...more

SEC Exam Priorities for 2016

The SEC’s Office of Compliance Inspections and Examinations or OCIE announced its examination priorities for 2016. Those priorities generally “reflect certain practices and products that OCIE perceives to present potentially...more

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