InfoBytes, February 17, 2012 - A Weekly In-depth review of news & developments in the financial services industry.

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Topics In This Issue

Excerpt from BuckleySandler Launches InfoBytes Blog

We are pleased to announce the firm's first ever blog - an on-line version of this newsletter. In addition to regular "bytes," the blog will contain additional real-time firm content and commentary on news and developments affecting financial services providers and other financial system participants. Click here to visit the blog and sign up to receive RSS feeds. Of course, we will continue to publish our weekly InfoBytes newsletter. We hope that you will find this new resource helpful and welcome any feedback, comments, or suggestions you might have on how we can do a better job in sharing critical developments of interest. www.infobytesblog.com

Excerpt from Federal Issues

CFPB Proposes Rule to Define "Larger Participants" in the Consumer Debt Collection and Consumer Reporting Markets. On February 16, the CFPB released a proposed rule to define "larger participants" in the markets for consumer debt collection and consumer reporting, thereby beginning the process by which the CFPB will determine which such entities are subject to its supervision. In short, the proposal uses annual receipts as the metric for determining larger participants. Under the Dodd-Frank Act, the CFPB has authority to supervise, regardless of size, nonbanks that provide to consumers (i) origination, brokerage, or servicing of residential mortgage loans secured by real estate, and related mortgage loan modification or foreclosure relief services; (ii) private education loans; and (iii) payday loans. The CFPB also has the power to supervise "larger participants" in any other market for consumer financial products or services, and the Act grants the CFPB authority to define "larger participants." In this first effort to define larger participants in specific markets, the CFPB proposes to supervise debt collectors with more than $10 million in annual receipts from debt collection activities, which would cover approximately 175 debt collection firms that collectively account for 63 percent of annual receipts from the debt collection market. Consumer reporting agencies with more than $7 million in annual receipts from consumer reporting activities

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