BuckleySandler LLP

6 Record Search Lessons From $43M Clydesdale Bank Penalty

Clydesdale Bank PLC was recently hit with a more-than-$43 million fine, largely because it failed to search for documents that should have been subject to its destruction policy, and for misleading consumers and its regulators…more

Banks, Corporate Fines, Document Destruction, Document Management, Document Retention Policies

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SEC Cooperation Is Still More Art Than Science

The quest for individual cooperation credit from the U.S. Securities and Exchange Commission is more of an art than a science, involving outcomes based largely on subjective judgments and a process that resists definition and…more

Compliance, Corporate Counsel, Enforcement Actions, Investigations, Mary Jo White

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How to Handle a Government Investigation: 13 Things You Should You Do Immediately If the Government Comes Knocking

Actions you take, or don’t take, in the early hours of a government investigation can have costly and far-reaching consequences for a company. At the root of this is the importance of having a plan in place should your company…more

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The SAFE Act's Unlevel Playing Field, NonDepository Mortgage Lenders Face Much Steeper Compliance Costs Under the SAFE Act's Licensing Provisions

Since Congress passed the Secure and Fair Enforcement for Mortgage Licensing Act of 2008 (the SAFE Act), mortgage loan originators and non-depository mortgage companies have learned that the promised uniformity of regulation…more

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Special Alert: CFPB Finalizes Rule to Oversee Nonbank Auto Lenders

On June 10, the CFPB issued its final rule to oversee “larger participant” nonbank auto finance companies. Although the CFPB received significant feedback during the comment period, the final rule is nearly identical to that…more

Automotive Loans, CFPB, Debt Collection, ECOA, Federal Register

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Special Alert: CFPB Issues Proposal to Delay TRID Rule Until October 3

The CFPB issued a proposed rule today to delay the effective date of the TILA-RESPA Integrated Disclosure (“TRID”) rule, including all amendments, from August 1 to October 3, 2015. The proposed delayed effective date is two…more

CFPB, Effective Date, Proposed Regulation, RESPA, TILA

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Special Alert: CFPB Issues Proposal to Delay TRID Rule Until October 3

The CFPB issued a proposed rule today to delay the effective date of the TILA-RESPA Integrated Disclosure (“TRID”) rule, including all amendments, from August 1 to October 3, 2015. The proposed delayed effective date is two…more

CFPB, Effective Date, Proposed Regulation, RESPA, TILA

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CFPB’s New ‘‘Responsible Conduct’’ Guidelines: Will They Incentivize Greater Self-Reporting And Self-Regulation By Consumer Finance Firms?

On June 25, 2013, the Consumer Financial Protection Bureau (CFPB or the Bureau) issued CFPB Bulletin 2013-6, titled ‘‘Responsible Business Conduct: Self-Policing, Self-Reporting, Remediation, and Cooperation.’’ The CFPB issued…more

CFPB, Compliance, Enforcement, Self-Regulatory Organizations, Self-Reporting

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InfoBytes Special Alert: CFPB Guidance States That Successors Are Not Subject To The ATR/QM Rule

On July 8, 2014, the CFPB issued an interpretive rule stating that the addition of a successor as an obligor on a mortgage does not trigger the Ability-to-Repay/Qualified Mortgage Rule (“ATR/QM Rule”) requirements if the…more

Beneficiaries, CFPB, Creditors, Mortgages, Regulation Z

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Special Alert: CFPB Launches First Monthly Complaint Report Providing Snapshot of Consumer Trends

On June 16, 2015, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) launched the first in a new series of monthly complaint reports highlighting key trends from consumer complaints submitted to the CFPB. Importantly,…more

Banking Sector, Banks, CFPB, Consumer Complaint System, Financial Institutions

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Starter Interrupters Expose Lenders To SCRA Risks

Individuals often take great care to make a good impression on a first date, but sometimes that’s just not possible. Oscar Fabela Jr. was walking his date back to his car after a movie when he found that his car would not start…more

Automotive Industry, Automotive Loans, DOJ, Financial Institutions, GPS

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Petitions to Modify or Set Aside CFPB Civil Investigative Demands (CIDs): Analysis of Recent Decisions

The Consumer Financial Protection Bureau (CFPB) has been using Civil Investigative Demands (CIDs) to investigate whether financial institutions are engaging in conduct that violates consumer financial laws. Two recent decisions…more

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Fair Lending Principles Must Underpin Loss Mit

The Obama Administration and Congress have searched for foreclosure alternatives to address the increasing number of defaulting residential mortgage loans, which rose to 9.47% in the fourth quarter of 2009. Some of these…more

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US v. Heinz May Bolster Expansive FIRREA Interpretation

The U.S. Department of Justice’s aggressive use of the Financial Institutions Reform, Recovery, and Enforcement Act to sue banks for fraud just received an unexpected boost, and from an unlikely source: In a criminal case…more

DOJ, Financial Institutions, FIRREA, Fraud, Municipal Bonds

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The New "Independent Ability to Pay" Requirement for Open-End Credit Under the Federal Reserve Board's Reg Z

The March 18, 2011 Regulation Z amendments adopted by the Federal Reserve Board clarify aspects of the open-end credit card rules adopted to implement changes to the Truth in Lending Act, under the Credit Card Accountability,…more

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Congress Could Be Coming For Dietary Supplements Soon

The next chapter in the saga of New York State Attorney General Eric T. Schneiderman's investigation of the dietary supplements industry may take place on Capitol Hill. On April 2, Schneiderman and the state attorneys general of…more

Attorney Generals, Dietary Supplements, FDA, Government Investigations

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What FCC’s Transparency Rule Means For Internet Privacy

There has been extensive coverage of the Federal Communication Commission’s new Open Internet Order, including questions about its ultimate fate, given pending court challenges. One element of the order that has not gotten…more

Broadband, Disclosure Requirements, FCC, Internet Privacy, ISPs

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Communicating with Family Members After the Death of a Customer

Your bank customer has died. Her husband, who is well known to the bank, calls to discuss his deceased wife’s account and seeks to “add” his name to the account so he can access some of the funds for funeral expenses. You would…more

Banking Sector, Banks, Beneficiaries, Deceased

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Spotlight on the Military Lending Act, Part 2: Planning for Compliance

Compliance with the revised Department of Defense (“DoD”) regulations under the Military Lending Act (“MLA”) is not mandatory until October 3, 2016 or, for most credit cards, until October 3, 2017. However, as the recent…more

Automotive Industry, Automotive Loans, Compliance, Consumer Lenders, Disclosure Requirements

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Special Alert: CFPB Finalizes Rule to Oversee Nonbank Auto Lenders

On June 10, the CFPB issued its final rule to oversee “larger participant” nonbank auto finance companies. Although the CFPB received significant feedback during the comment period, the final rule is nearly identical to that…more

Automotive Loans, CFPB, Debt Collection, ECOA, Federal Register

See All Updates »

Special Alert: CFPB Launches First Monthly Complaint Report Providing Snapshot of Consumer Trends

On June 16, 2015, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) launched the first in a new series of monthly complaint reports highlighting key trends from consumer complaints submitted to the CFPB. Importantly,…more

Banking Sector, Banks, CFPB, Consumer Complaint System, Financial Institutions

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Spotlight on the Military Lending Act: Did the Final Rule Improve on the Proposal?

On July 22, 2015, the Department of Defense (“Department”) released its final rule amending the regulations that implement the Military Lending Act (“MLA”), which means that a wider range of credit products—including open-end…more

Banking Sector, Banks, Borrowers, CARD Act, Compliance

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Special Alert: CFPB Issues Proposal to Delay TRID Rule Until October 3

The CFPB issued a proposed rule today to delay the effective date of the TILA-RESPA Integrated Disclosure (“TRID”) rule, including all amendments, from August 1 to October 3, 2015. The proposed delayed effective date is two…more

CFPB, Effective Date, Proposed Regulation, RESPA, TILA

See All Updates »

Special Alert: CFPB Reports On The Findings From Its "Know Before You Owe" eClosing Pilot Project

In 2014, the Consumer Financial Protection Bureau (“CFPB”) initiated an eClosing pilot program. The eClosing pilot was intended to assist the CFPB in evaluating the use of electronic records and signatures in the residential…more

Banking Sector, Banks, Borrowers, CFPB, Closing Documents

See All Updates »

Special Alert: CFPB Finalizes Rule to Oversee Nonbank Auto Lenders

On June 10, the CFPB issued its final rule to oversee “larger participant” nonbank auto finance companies. Although the CFPB received significant feedback during the comment period, the final rule is nearly identical to that…more

Automotive Loans, CFPB, Debt Collection, ECOA, Federal Register

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HELOCKed: Putative Class Survives Dismissal Under "Fair Lending" Standard

It was a not unexpected result at the motion to dismiss stage: On June 30, 2011, the Northern District of Illinois permitted borrowers in a multi-district litigation putative class action to go forward with claims that JPMorgan…more

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Congress Could Be Coming For Dietary Supplements Soon

The next chapter in the saga of New York State Attorney General Eric T. Schneiderman's investigation of the dietary supplements industry may take place on Capitol Hill. On April 2, Schneiderman and the state attorneys general of…more

Attorney Generals, Dietary Supplements, FDA, Government Investigations

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Why Getting FHA’s Loan Servicing Rules 'Right' Matters

In recent years, servicing U.S. Federal Housing Administration- insured loans has become risky business. The U.S. Department of Housing and Urban Development has heightened its monitoring and enforcement, with servicers…more

CFPB, Compliance, DOJ, Fannie Mae, FHA

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Special Alert: CSBS Issues Policy, Draft Model Regulatory Framework, and Request for Comment Regarding State Regulation of Virtual Currency

On December 16, 2014, the Conference of State Bank Supervisors (“CSBS”) issued a Policy on State Regulation of Virtual Currency (the “Policy”), Draft Model Regulatory Framework, and a request for public comment regarding the…more

Banking Sector, Banks, CSBS, Public Comment, Regulatory Agenda

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Why Getting FHA’s Loan Servicing Rules 'Right' Matters

In recent years, servicing U.S. Federal Housing Administration- insured loans has become risky business. The U.S. Department of Housing and Urban Development has heightened its monitoring and enforcement, with servicers…more

CFPB, Compliance, DOJ, Fannie Mae, FHA

See All Updates »

Special Alert: CFPB Finalizes Rule to Oversee Nonbank Auto Lenders

On June 10, the CFPB issued its final rule to oversee “larger participant” nonbank auto finance companies. Although the CFPB received significant feedback during the comment period, the final rule is nearly identical to that…more

Automotive Loans, CFPB, Debt Collection, ECOA, Federal Register

See All Updates »

Special Alert: CFPB Launches First Monthly Complaint Report Providing Snapshot of Consumer Trends

On June 16, 2015, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) launched the first in a new series of monthly complaint reports highlighting key trends from consumer complaints submitted to the CFPB. Importantly,…more

Banking Sector, Banks, CFPB, Consumer Complaint System, Financial Institutions

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FCPA: Were the Sting Trials Doomed From the Start?

The authors had front row seats to the challenges facing the government in the Foreign Corrupt Practices Act (FCPA) Sting trials, having represented a client who obtained a mistrial when the jury failed to reach a unanimous…more

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Special Alert: Second Circuit Will Not Rehear Madden Decision That Threatens to Upset Secondary Credit Markets

Two months ago we issued a Special Alert regarding the decision of the Court of Appeals for the Second Circuit in Madden v. Midland Funding, LLC, which held that a nonbank entity taking assignment of debts originated by a…more

Consumer Lenders, FDIC, Financial Institutions, Financial Services Industry, Loan Agreements

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SAFE or Out? Who's In, Who's Not Under the SAFE Act?

Since the Secure and Fair Enforcement for Mortgage Licensing Act was signed into law in 2008, the states have adopted licensing laws compliant with the new federal standard, but questions remain about who is covered by the SAFE…more

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Infobytes Special Alert: CFPB Bulletin Re-Emphasizes Focus On Mortgage Servicing Transfers

On August 19, 2014, the CFPB issued Bulletin 2014-01 to address “potential risks to consumers that may arise in connection with transfers of residential mortgage servicing rights.” The bulletin, which is the latest in a series…more

CFPB, Mortgage Servicers, Mortgage Servicing Rules, Mortgages, Real Estate Transfers

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CFPB In Focus: Navigating Investigational Hearings

The Consumer Financial Protection Bureau has been actively engaged in investigations of banks and nonbanks since it was established nearly three years ago. To further its mission “to ensure that consumer financial markets…more

Banks, CFPB, Compliance, Enforcement, Investigations

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Lender-Placed Insurance Actions Continue to Simmer

Litigation and regulatory scrutiny surrounding lender-placed insurance (“LPI”) practices, initiated in large part on the heels of the mortgage crisis, continues to simmer. While the largest LPI class actions have settled,…more

CFPB, Class Action, Fannie Mae, FHFA, Freddie Mac

See All Updates »

Starter Interrupters Expose Lenders To SCRA Risks

Individuals often take great care to make a good impression on a first date, but sometimes that’s just not possible. Oscar Fabela Jr. was walking his date back to his car after a movie when he found that his car would not start…more

Automotive Industry, Automotive Loans, DOJ, Financial Institutions, GPS

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Blocking CAFA Remand: Lessons From A Prevailing Defendant

The Class Action Fairness Act[1] was designed, at least in part, to allow defendants to remove to federal court class actions strategically filed by plaintiffs in sympathetic state court jurisdictions. This newfound ability for…more

CAFA, Federal Jurisdiction, Home State Exception, Jurisdiction, Remand

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Special Alert: CFPB Releases Outline Of Proposed Rule For Payday, Vehicle Title, And Similar Loans

On March 26, the CFPB announced that it is considering proposing a rule to “end payday debt traps” and released several related documents, including a fact sheet and an outline of the proposal that will be presented to a panel…more

CFPB, Consumer Lenders, Payday Loans, Proposed Regulation, SBREFA

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FCPA: Recent Enforcement Activity Sounds Warning for Financial Services Industry

"When Cheryl J. Scarboro, Chief of the U.S. Securities and Exchange Comission's (SEC) Foreign Corrupt Practices Act (FCPA) enforcement unit, remarked in November 2010 that her unit "will continue to focus on industry-wide sweeps…more

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Treading Beyond the Iota of Fear: eDiscovery of the Internet of Things

First came the Industrial Revolution. Then the Internet Revolution. And today we have made a firm step into the dawn of a third revolution called the ‘‘Internet of Things’’ or ‘‘IoT.’’ Or at least this is how IoT’s arrival was…more

Discovery, Federal Rules of Civil Procedure, Internet of Things, Popular, Technology

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Infobytes Special Alert: CFPB Bulletin Re-Emphasizes Focus On Mortgage Servicing Transfers

On August 19, 2014, the CFPB issued Bulletin 2014-01 to address “potential risks to consumers that may arise in connection with transfers of residential mortgage servicing rights.” The bulletin, which is the latest in a series…more

CFPB, Mortgage Servicers, Mortgage Servicing Rules, Mortgages, Real Estate Transfers

See All Updates »

Congress Could Be Coming For Dietary Supplements Soon

The next chapter in the saga of New York State Attorney General Eric T. Schneiderman's investigation of the dietary supplements industry may take place on Capitol Hill. On April 2, Schneiderman and the state attorneys general of…more

Attorney Generals, Dietary Supplements, FDA, Government Investigations

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Special Alert Update: OCC Revises Guidance Regarding Consumer Protection Requirements to Overdraft Lines and Protection Services

On March 6, 2015, the OCC issued its revised “Deposit-Related Credit” booklet (“DRC booklet”) of the Comptroller’s Handbook, which replaced the “Deposit-Related Consumer Credit” booklet issued on February 11, 2015 (previously…more

Banks, Consumer Financial Products, Deposit Accounts, Guidance Update, OCC

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DOJ's Pursuit Of Admissions — And The Risks Of Settling

On March 19, 2015, the U.S. Attorney’s Office for the Southern District of New York announced a proposed settlement of a civil fraud lawsuit against a large financial institution (bank). As with many of the U.S. Department of…more

Bank Fraud, Banks, Corporate Officers, DOJ, Enforcement Actions

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Special Alert: Second Circuit Will Not Rehear Madden Decision That Threatens to Upset Secondary Credit Markets

Two months ago we issued a Special Alert regarding the decision of the Court of Appeals for the Second Circuit in Madden v. Midland Funding, LLC, which held that a nonbank entity taking assignment of debts originated by a…more

Consumer Lenders, FDIC, Financial Institutions, Financial Services Industry, Loan Agreements

See All Updates »

Spotlight on the Military Lending Act, Part 2: Planning for Compliance

Compliance with the revised Department of Defense (“DoD”) regulations under the Military Lending Act (“MLA”) is not mandatory until October 3, 2016 or, for most credit cards, until October 3, 2017. However, as the recent…more

Automotive Industry, Automotive Loans, Compliance, Consumer Lenders, Disclosure Requirements

See All Updates »

InfoBytes Special Alert: Lessons Learned From Arab Bank’s U.S. Anti-Terrorism Act Verdict

On September 22, 2014, following a two-month trial, a federal jury in the Eastern District of New York ruled in favor of a group of 297 individual plaintiffs in a civil suit accusing Arab Bank PLC, headquartered in Amman,…more

Anti-Terrorism Act, Foreign Banks, Terrorism Funding

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Rising Tide of Operational Risk Demands Due Diligence in Vendor Selection

Considering the potential liability associated with outsourcing by the mortgage banking and mortgage servicing industries, as witnessed by widely publicized high-dollar settlements in government enforcement actions, recent…more

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Special Alert: CFPB Finalizes Rule to Oversee Nonbank Auto Lenders

On June 10, the CFPB issued its final rule to oversee “larger participant” nonbank auto finance companies. Although the CFPB received significant feedback during the comment period, the final rule is nearly identical to that…more

Automotive Loans, CFPB, Debt Collection, ECOA, Federal Register

See All Updates »

DOJ's Pursuit Of Admissions — And The Risks Of Settling

On March 19, 2015, the U.S. Attorney’s Office for the Southern District of New York announced a proposed settlement of a civil fraud lawsuit against a large financial institution (bank). As with many of the U.S. Department of…more

Bank Fraud, Banks, Corporate Officers, DOJ, Enforcement Actions

See All Updates »

Lender-Placed Insurance Actions Continue to Simmer

Litigation and regulatory scrutiny surrounding lender-placed insurance (“LPI”) practices, initiated in large part on the heels of the mortgage crisis, continues to simmer. While the largest LPI class actions have settled,…more

CFPB, Class Action, Fannie Mae, FHFA, Freddie Mac

See All Updates »

InfoBytes Special Alert: Lessons Learned From Arab Bank’s U.S. Anti-Terrorism Act Verdict

On September 22, 2014, following a two-month trial, a federal jury in the Eastern District of New York ruled in favor of a group of 297 individual plaintiffs in a civil suit accusing Arab Bank PLC, headquartered in Amman,…more

Anti-Terrorism Act, Foreign Banks, Terrorism Funding

See All Updates »

Special Alert: CFPB Finalizes Rule to Oversee Nonbank Auto Lenders

On June 10, the CFPB issued its final rule to oversee “larger participant” nonbank auto finance companies. Although the CFPB received significant feedback during the comment period, the final rule is nearly identical to that…more

Automotive Loans, CFPB, Debt Collection, ECOA, Federal Register

See All Updates »

Expanded Criminal Enforcement in the Financial Services Industry

Since the economic meltdown began in 2008, the media have waged a relentless attack on the financial industry as the greedy culprit. "So where are all the prosecutions that we were promised?" the white-collar bar has wondered…more

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Special Alert: CFPB Issues Proposal to Delay TRID Rule Until October 3

The CFPB issued a proposed rule today to delay the effective date of the TILA-RESPA Integrated Disclosure (“TRID”) rule, including all amendments, from August 1 to October 3, 2015. The proposed delayed effective date is two…more

CFPB, Effective Date, Proposed Regulation, RESPA, TILA

See All Updates »

Special Alert: CFPB Launches First Monthly Complaint Report Providing Snapshot of Consumer Trends

On June 16, 2015, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) launched the first in a new series of monthly complaint reports highlighting key trends from consumer complaints submitted to the CFPB. Importantly,…more

Banking Sector, Banks, CFPB, Consumer Complaint System, Financial Institutions

See All Updates »

Why Getting FHA’s Loan Servicing Rules 'Right' Matters

In recent years, servicing U.S. Federal Housing Administration- insured loans has become risky business. The U.S. Department of Housing and Urban Development has heightened its monitoring and enforcement, with servicers…more

CFPB, Compliance, DOJ, Fannie Mae, FHA

See All Updates »

What FCC’s Transparency Rule Means For Internet Privacy

There has been extensive coverage of the Federal Communication Commission’s new Open Internet Order, including questions about its ultimate fate, given pending court challenges. One element of the order that has not gotten…more

Broadband, Disclosure Requirements, FCC, Internet Privacy, ISPs

See All Updates »

Special Alert: USDA-RHS Proposes Its Own QM Rule

On March 5, 2015, the USDA-RHS released a proposed rule to amend the regulations for the Single Family Housing Guaranteed Loan Program (SFHGLP) to provide that a loan guaranteed by USDA-RHS is a QM if it meets certain…more

Mortgage Lenders, Mortgage Loan Originators, Mortgages, Single Family Housing

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The Brave New World of Consumer Compliance

Compliance has changed from a checklist-based, technical science to a principles-based, qualitative art. Gone are the days when an institution that is compliant with all substantive consumer protection laws can breathe easy;…more

Chief Compliance Officers, Compliance, Popular, UDAAP

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US v. Heinz May Bolster Expansive FIRREA Interpretation

The U.S. Department of Justice’s aggressive use of the Financial Institutions Reform, Recovery, and Enforcement Act to sue banks for fraud just received an unexpected boost, and from an unlikely source: In a criminal case…more

DOJ, Financial Institutions, FIRREA, Fraud, Municipal Bonds

See All Updates »

Spotlight on Vendor Management: “Brother’s Keeper” Enforcement Pattern Becoming the Norm

Two regulatory enforcement matters announced in April offer a view into the current mindset of regulators in the ever-evolving world of vendor management. First, the Federal Communications Commission (FCC) announced a $25…more

CFPB, Debt Collection, Enforcement Actions, FCC, Personally Identifiable Information

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The Board of Directors and Cybersecurity: Setting up the Right Structure

Security breaches have become a staple of the daily news. A national restaurant chain announced in August 2014, that a payment card processing system breach involved 33 restaurants in 18 states and that the incident lasted…more

Board of Directors, Cybersecurity, Data Breach, Data Protection, Hackers

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Special Alert: CFPB Launches First Monthly Complaint Report Providing Snapshot of Consumer Trends

On June 16, 2015, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) launched the first in a new series of monthly complaint reports highlighting key trends from consumer complaints submitted to the CFPB. Importantly,…more

Banking Sector, Banks, CFPB, Consumer Complaint System, Financial Institutions

See All Updates »

Infobytes Special Alert: FinCEN Publishes Long - Awaited Proposed Customer Due Diligence Requirements

On August 4, 2014, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) published a Notice of Proposed Rulemaking ("NPRM") that would amend existing Bank Secrecy Act (“BSA”) regulations intended…more

Bank Secrecy Act, Beneficial Owner, CDD, Covered Financial Institutions, FinCEN

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Caveat Emptor or Caveat Vendor? The Evolution of Unfairness in Federal Consumer Protection Law

Under the Federal Trade Commission’s original interpretation of unfair or deceptive acts or practices law, financial institutions could feel some sense of security that, if they provided a consumer with a clear understanding of…more

CFPB, China, Data Brokers, Data Controller, FCRA

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Special Alert: CFPB Reports On The Findings From Its "Know Before You Owe" eClosing Pilot Project

In 2014, the Consumer Financial Protection Bureau (“CFPB”) initiated an eClosing pilot program. The eClosing pilot was intended to assist the CFPB in evaluating the use of electronic records and signatures in the residential…more

Banking Sector, Banks, Borrowers, CFPB, Closing Documents

See All Updates »

New Fair Lending Initiatives

The U.S. Department of Housing and Urban Development, the New York State Banking Department, and the Federal Trade Commission have emerged as enforcers of the laws prohibiting lending discrimination on the bases of race, color,…more

See All Updates »

Special Alert: CFPB Launches First Monthly Complaint Report Providing Snapshot of Consumer Trends

On June 16, 2015, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) launched the first in a new series of monthly complaint reports highlighting key trends from consumer complaints submitted to the CFPB. Importantly,…more

Banking Sector, Banks, CFPB, Consumer Complaint System, Financial Institutions

See All Updates »

Special Alert: CFPB Reports On The Findings From Its "Know Before You Owe" eClosing Pilot Project

In 2014, the Consumer Financial Protection Bureau (“CFPB”) initiated an eClosing pilot program. The eClosing pilot was intended to assist the CFPB in evaluating the use of electronic records and signatures in the residential…more

Banking Sector, Banks, Borrowers, CFPB, Closing Documents

See All Updates »

A New Defense Against Municipal Disparate Impact Claims

Banks and non-bank lenders face a variety of fair lending disparate impact claims, which allege unintentional and unfavorable disparate impacts of otherwise neutral policies or practices on minority borrowers. Regulators,…more

ADEA, Age Discrimination, Disparate Impact, Fair Housing Act, Municipalities

See All Updates »

Spotlight on the Military Lending Act, Part 2: Planning for Compliance

Compliance with the revised Department of Defense (“DoD”) regulations under the Military Lending Act (“MLA”) is not mandatory until October 3, 2016 or, for most credit cards, until October 3, 2017. However, as the recent…more

Automotive Industry, Automotive Loans, Compliance, Consumer Lenders, Disclosure Requirements

See All Updates »

Infobytes Special Alert: CFPB Bulletin Re-Emphasizes Focus On Mortgage Servicing Transfers

On August 19, 2014, the CFPB issued Bulletin 2014-01 to address “potential risks to consumers that may arise in connection with transfers of residential mortgage servicing rights.” The bulletin, which is the latest in a series…more

CFPB, Mortgage Servicers, Mortgage Servicing Rules, Mortgages, Real Estate Transfers

See All Updates »

Treading Beyond the Iota of Fear: eDiscovery of the Internet of Things

First came the Industrial Revolution. Then the Internet Revolution. And today we have made a firm step into the dawn of a third revolution called the ‘‘Internet of Things’’ or ‘‘IoT.’’ Or at least this is how IoT’s arrival was…more

Discovery, Federal Rules of Civil Procedure, Internet of Things, Popular, Technology

See All Updates »

Special Alert: Second Circuit Will Not Rehear Madden Decision That Threatens to Upset Secondary Credit Markets

Two months ago we issued a Special Alert regarding the decision of the Court of Appeals for the Second Circuit in Madden v. Midland Funding, LLC, which held that a nonbank entity taking assignment of debts originated by a…more

Consumer Lenders, FDIC, Financial Institutions, Financial Services Industry, Loan Agreements

See All Updates »

InfoBytes Special Alert: Lessons Learned From Arab Bank’s U.S. Anti-Terrorism Act Verdict

On September 22, 2014, following a two-month trial, a federal jury in the Eastern District of New York ruled in favor of a group of 297 individual plaintiffs in a civil suit accusing Arab Bank PLC, headquartered in Amman,…more

Anti-Terrorism Act, Foreign Banks, Terrorism Funding

See All Updates »

Contact

1250 24th Street, NW Suite 700
Washington, D.C. 20037, United States

Contact: Ezra Crawford

  • 202•349•8000
  • 202•349•8080

Areas of Practice
  • Appellate Practice
  • Bankruptcy
  • Business Organizations
  • Business Torts
  • Class Action
  • Commercial Law & Contracts
  • Criminal Law
  • Finance & Banking
  • Government
  • Insurance
  • International Law & Trade
  • Litigation
  • Mergers & Acquisitions
  • Privacy
  • Real Estate
  • Science, Computers, & Tech
  • Securities Law
See more
Locations
Other U.S. Locations
  • California
  • D.C.
  • Illinois
  • New York
Other Countries
  • United Kingdom
Number of Attorneys

100+ Attorneys

This profile may constitute attorney advertising. Prior results do not guarantee a similar outcome. Any correspondence with this profile holder does not constitute a client/attorney relationship. Neither the content on this profile nor transmissions between you and the profile holder through this profile are intended to provide legal or other advice or to create an attorney-client relationship.

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