Takeaways for Banks from the CFPB’s Recent Consent Order on Garnishment Orders
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President Ronald Reagan once said, “Trust, but verify,” echoing a Russian proverb to describe the relationship moving forward with the Soviet Union. The saying loosely translates into proceeding cautiously when someone is...more
“Business Email Compromise Scams” or “BEC scams” typically target companies that conduct wire transfers with entities abroad. For example, a fraudster may use an email address that is very similar to that of a business’s...more
This survey summarizes several recent developments affecting bank deposits and payment systems. These include payments-related consent orders and enforcement actions by the Consumer Financial Protection Bureau (“CFPB”) and...more
This week I am exploring the Wells Fargo Department of Justice (DOJ) and Securities and Exchange Commission (SEC) settlement of $3 billion. The case presents multiple lessons for the compliance professional and one very large...more
I did not think that the Wells Fargo fraudulent accounts scandal could get worse for the bank. Boy was I wrong. Last week, in a Press Release, the Department of Justice (DOJ) announced a that Wells Fargo & Company and its...more
In an all too familiar story, an insurance company's managing agent was tricked into transferring nearly $2 million into the fraudster's account at Wells Fargo Bank. The plaintiffs then sued the bank alleging that after...more
While electronic funds transfer is considered a convenient and quicker way to process payments and receive funds on construction projects, this practice presents significant risk to project participants. Contractual and...more
In Compass Bank v. Calleja-Ahedo, an identity thief drained the plaintiff’s bank account through a series of fraudulent transactions in 2012 and 2013, and the plaintiff sued his bank to recover the stolen funds. No. 17-0065,...more
The Times gives us an intriguing long read on Uber’s Travis Kalanick, the controversial CEO whose vision has helped propel the ride-hailing company even as his no-limits approach has led the company into months of crisis....more
You may not recognize the full name, John Warren Geils Jr., but you probably do recognize the name J. Geils, as in the J. Geils Band, who died this week. J. Geils was ubiquitous in the 70s and early 80s with, as noted by an...more
Today, we celebrate The Eagles most famous song, Hotel California. It all started with a Don Felder cord progression and according to the Financial Times (FT) column The Life of a Song, it had a “fusion of Hispanic melody and...more
The more you learn about Wells Fargo’s culture problems, the more difficult the problems become. But you have to start somewhere, and assuming that Wells Fargo really is committed to addressing the serious problems they face,...more
Activist investor Carl Icahn has taken a sizeable stake in Bristol-Myers Squibb, a move that reportedly caught execs at the drugmaker unawares and sets the stage for a potential sale....more
Streetwise traces Italy’s Banca Monte dei Paschi’s big-time current troubles to a meeting nearly a decade ago and the ill-fated deal reached there that’s led to the downfall of 3 (and probably 4) of the world’s biggest and...more
Federal regulators unveiled a proposal yesterday that would push the country’s biggest banks and other “critical financial companies” to shore up cybersecurity protocols, to prevent hacks, and to have a recovery plan at the...more
I continue my celebration of Bob Dylan, Nobel Laureate, by reflecting on what many consider to be his greatest recording, Like a Rolling Stone. In 2004, Rolling Stone magazine named it as the greatest song of all time....more
Compliance and enforcement headlines have focused on the Wells Fargo scandal. And for good reason. On September 8, 2016, the Consumer Financial Protection Bureau, the Comptroller of the Currency and the Los Angeles...more
Crimson flames tied through my ears... Rollin’ high and mighty traps... Pounced with fire on flaming roads... Using ideas as my maps... “We’ll meet on edges, soon,” said I... Proud ‘neath heated...more
The Wells Fargo scandal represents a textbook case of compliance and culture failures. Recently, the scandal and Wells Fargo’s defensive crisis management strategy resulted in CEO Stumpf’s resignation. Stumpf’s demise was...more
Like a hot new underground nightclub [I presume. Not exactly my scene], Marcus—Goldman Sachs’ new online lending platform aimed at the consumer banking segment—requires a password. Goldman’s reportedly sending out the...more
Holding companies appear to be an important new feature of the “living will” revisions the big banks have been making in an effort to appease the Fed and FDIC’s efforts to stamp out “too big to fail” entities. The idea is for...more
Corporate culture is singular to companies. Yet it also varies from industry to industry. I have been considering why the Wells Fargo scandal has engendered such public outrage. You could consider many factors, such as the...more
We are in October and I am looking forward to my annual exploration of classic monster movies beginning this coming Friday. This year I decided to go back to the roots by watching the 30s and 40s classic Universal monster...more
The Journal gives us a closer look at Italy’s Monte dei Paschi—the world’s oldest bank (founded in 1472)—that’s deeply tied to Siena and that’s threatening to drag the whole of the region’s economy down with it if it fails,...more