Compliance Consumer Financial Protection Bureau

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
News & Analysis as of

Coming Soon... New Closing (no, Consummation...) Rules!

What?! We can’t call it a closing anymore? Under new federal regulations regarding the Truth in Lending Act (“TILA”) and the Real Estate Settlement Procedures Act (“RESPA”), the terminology for a “closing” or “settlement” is...more

CFPB Signals Future Regulation in the Payment Processing Industry

On July 9, 2015, the Consumer Financial Protection Bureau (CFPB) issued a set of “consumer protection principles” for the financial industry as it develops new, faster payment processing systems. Last November, CFPB Director...more

Treasury Request for Public Input on Expanding Access to Credit through Online Marketplace Lending

On July 20, the Department of the Treasury published a Notice and Request for Information (“RFI”) seeking comment on various aspects of online marketplace lending, including – - the business models and products offered...more

How to Respond to a CFPB Civil Investigative Demand

The Consumer Financial Protection Bureau (“CFPB”) was created to enforce the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“Dodd-Frank”) and various consumer finance laws (e.g., Equal Credit Opportunity...more

Auto Finance Company Agrees to Change Dealer Compensation Policy to Settle CFPB and DOJ Fair Lending Claims

To resolve charges by the Consumer Federal Protection Bureau (CFPB) and the Department of Justice (DOJ) that it engaged in unlawful discrimination in violation of the Equal Credit Opportunity Act (ECOA), American Honda...more

The CFPB and the Business of Insurance: An Analysis of the Scope of CFPB’s Authority Over Insurance Sales

In 2014, the Bureau of Consumer financial Protection (CFPB) issued an enforcement order against a bank and its service provider for allegedly misleading sales of insurance. That order was based on the CFPB’s power to prohibit...more

CFPB, 47 State AGs, and District of Columbia Announce $216 Million Settlement to Resolve Credit Card Debt-Buying Investigation

On July 8, the CFPB along with 47 state attorneys general and DC announced an agreement with a major bank to resolve allegations that it sold faulty credit card “zombie debts” to third-party debt buyers, which included...more

CFPB Shifts Focus to Auto Lending Industry

Auto lenders and servicers be advised: the Consumer Financial Protection Bureau (CFPB) turns its lonely eyes to you. On June 17, 2015, the CFPB brought an action in the Southern District of Ohio against Security National...more

Are Public Companies Required to Disclose that the Government is Investigating Them?

For many public companies, the first issue they have to confront after they receive a government subpoena or Civil Investigative Demand (“CID”) is whether to disclose publicly that they are under investigation. Curiously, the...more

Lenders Get TRID Reprieve Thanks to CFPB Admin Error

Why it matters - An “administrative error” on the part of the Consumer Financial Protection Bureau (CFPB) may have been the best news lenders received in a long time. On August 1, the new TRID (TILA-RESPA Integrated...more

Your Questions: The Role of the CCO - A Q&A Session About the Evolving Role of the Chief Compliance Officer

Last year we gathered Robert Chersi, Executive Director, Center for Global Governance, Reporting and Regulation at Pace University; Seth Rice, Assistant General Counsel – Compliance & Director of Global Ethics and Compliance...more

Inside Information: Understanding Consumer Complaint Topics as a Key Defense Against UDAAP

In 2010, the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) introduced the current version of unfair, deceptive, or abusive acts and practices (UDAAP), making it unlawful for any service provider...more

Supervisory Haiku-lights, Summer 2015

Break out the short shorts everybody: it’s summer! We know you could use a palate cleanser between the 50 Shades novels and Game of Thrones wikis you’re reading on the beach. Supervisory Haiku-lights to the rescue! The Summer...more

CFPB Proposes to Extend Know Before You Owe Rule Compliance to October

On June 24 the CFPB published its proposed rule for extending the effective date for implementation of the Know Before You Owe Rule to October 3, 2015. The public has until July 7...more

Locke Lord QuickStudy: CFPB Claims Sensitivity on Good-Faith TRID Compliance Efforts

On June 3, 2015, Consumer Financial Protection Bureau (CFPB) Director Richard Cordray responded to Congressional requests and industry pleadings for a grace period in enforcing the new TILA-RESPA Integrated Disclosures...more

A Look Behind The Compliance Headlines

In this Presentation: - Agenda - CFPB – Approach to Regulation - CFPB – Hot Mortgage Topics - Genuine Title, LLC, et al. - New Day Financial, LLC - American Preferred Lending, Flagship...more

CFPB Releases its Third Fair Lending Report to Congress

On April 28, 2015, the Consumer Financial Protection Bureau (the “CFPB” or “Bureau”), established in 2010 by The Dodd-Frank Wall Street Reform and Consumer Protection Act, issued its third Fair Lending Report (the “Report”)...more

CFPB announces proposals for limiting activities of payday lending market participants and other lenders: 6 questions answered

The CFPB has released proposals for a future payday loan rulemaking that will have a far-reaching impact on the $46 billion payday loan industry and on other markets. Under its proposals, the CFPB is offering industry...more

CFPB Takes Action for Deceptive Advertisement of "Free Checking"

Although the CFPB has focused its rulemaking and enforcement actions on mortgage servicing and lending, it recently entered into a consent order with M&T Bank regarding the deceptive advertising of free checking. The...more

OIG identifies five major CFPB management challenges

The joint Federal Reserve/CFPB Office of the Inspector General (OIG) recently issued its first listing of “major management challenges” facing the CFPB. These challenges represent what the OIG believes to be “the areas that,...more

CFPB Finalizes Rule To Limit Relief From Annual Privacy Notice Delivery Requirements

On October 20, the CFPB finalized its amendment to Regulation P, which requires that financial institutions meet specific consumer data-sharing requirements, including the delivery of annual privacy notices. Under the new...more

OIG Outlines Major CFPB Management Challenges

The Office of Inspector General, or OIG, of the Board of Governors of the Federal Reserve System has issued its first listing of major management challenges facing the CFPB. These challenges represent what OIG believes to be...more

Orrick's Financial Industry Week in Review

EBA Updates Single Rulebook Q&As - On October 17, the European Banking Authority (EBA) updated its Q&As on the single rulebook, publishing two new answers to questions relating to supervisory reporting and credit risk....more

CFPB Proposes No-Action Letter Policy for Innovative Products

The Consumer Financial Protection Bureau has proposed a no-action letter policy under which the agency would issue letters stating that its staff “has no present intention to recommend initiation of an enforcement or...more

Dodd-Frank News: October 2014: Dodd-Frank Wall Street Reform and Consumer Protection Act Update

In This Issue: - RECENT CASES .. Mortgage Servicing Rules .. Antiretaliation Provision ..Credit Default Swaps Antitrust Litigation ..CFPB Involvement in Litigation - IN THE...more

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