News & Analysis as of

FFIEC proposes new rating system

The Federal Financial Institutions Examination Council (FFIEC), whose members include the CFPB, is proposing a new uniform interagency consumer compliance rating system to reflect changes in consumer compliance supervision...more

Valuable Information Security Lessons from the Olympus Mortgage vs. Guaranteed Rate Case

Late last month a jury awarded Mount Olympus Mortgage Company (MOMC) more than $25 million for their claims against Guaranteed Rate (Guaranteed), which alleged Guaranteed along with other former employees of MOMC illegally...more

Cybersecurity: What You Must Know and What You Must Do

On February 1, 2016, the Federal Deposit Insurance Corporation (“FDIC”) published the Winter 2015 issue of Supervisory Insights. Not surprisingly, the first article dealt with the most important issue facing the financial...more

CFPB Publishes HMDA File Specifications for Data Collected in 2017 and 2018

On February 18, the Consumer Financial Protection Bureau (CFPB) and the Federal Financial Institutions Examination Council (FFIEC) published new “File Specifications” for data to be collected pursuant to the Home Mortgage...more

Reporting for Duty: HMDA Regs Finalized

Why it matters Reporting requirements for financial institutions under the Home Mortgage Disclosure Act (HMDA) regulations were finalized by the Consumer Financial Protection Bureau (CFPB), with most provisions of the...more

Transitional period and initial supervisory practice over TRID

The CFPB sent industry trade groups a letter on October 1, 2015 to address the approach of the Federal Financial Institutions Examination Council (FFIEC) member agencies during the initial months following the implementation...more

Transitional period and initial supervisory practice over TRID

The CFPB sent industry trade groups a letter on October 1, 2015 to address the approach of the FFIEC member agencies during the initial months following the implementation of the TILA-RESPA Integrated Disclosure (TRID) rule...more

EXPECT FOCUS: Onboard Technology, NAIC Cybersecurity, DOL, ACA Litigation, SEC Regulation (Vol. III, Summer 2015)

In This Issue: IN THE SPOTLIGHT - - Your Data Breach Collided With My Personal Injury Coverage LIFE INSURANCE - - Phantom Injury Dooms “Shadow Insurance” Case - Latest NAIC Cybersecurity News...more

Cordray Submits Letter to Trade Associations Regarding TRID Compliance

On October 1, CFPB Director Richard Cordray, on behalf of the FFIEC, responded to correspondence from the American Bankers Association and other trade associations seeking guidance as to their compliance with the Bureau’s...more

FFIEC Weighs in on Cybersecurity in Light of Unprecedented Risk of Cyber Threats

As financial institutions of all sizes continue to face unprecedented cybersecurity risk, the Federal Financial Institutions Examination Council (FFIEC) released its Cybersecurity Assessment Tool. The Assessment is...more

Corporate and Financial Weekly Digest - Volume X, Issue 38

SEC/CORPORATE - ISS Publishes Results of 2015–2016 Annual Global Policy Survey - On September 28, Institutional Shareholder Services (ISS), a leading proxy advisory firm, published the results of its 2015–2016...more

Financial Services Report, Fall 2015

BELTWAY - Straight Out of the Seventh Circuit The Seventh Circuit recently affirmed a lower court’s ruling that the SEC cannot be sued in district court to stop it from bringing an administrative action. Bebo v. SEC, No....more

Protecting financial institutions in cyberspace—U.S. financial regulators come up with a new tool kit to stem cyberthreats

The Federal Financial Institutions Examination Council (FFIEC) has recently developed a new tool to help U.S. financial institutions combat the increasing volume and sophistication of cyber attacks. To blunt threats to a...more

FFIEC Releases Cybersecurity Assessment Tool

Why it matters - As anticipated, the Federal Financial Institutions Examination Council (FFIEC) released its Cybersecurity Assessment Tool, providing a process for financial institutions' management to gauge their...more

FFIEC Cybersecurity Assessment Tool: Not Just For Financial Institutions

On June 30, 2015, the Federal Financial Institutions Examination Council (FFIEC) released its long anticipated Cybersecurity Assessment Tool (press release here). The FFIEC is a formal interagency organization empowered to...more

FFIEC’s Cybersecurity Assessment Tool: Guidance for CEOs and Boards - Senior Management and Boards Should Be Actively Addressing...

The Federal Financial Institutions Examination Council (FFIEC) released a Cybersecurity Assessment Tool (CAT) on June 30, 2015, to assist organizations in identifying cyber risks and assessing their cybersecurity...more

FFIEC’s Cybersecurity Assessment Tool: Guidance for CEOs and Boards - Senior Management and Boards Should Be Actively Addressing...

The Federal Financial Institutions Examination Council (FFIEC) released a Cybersecurity Assessment Tool (CAT) on June 30, 2015, to assist organizations in identifying cyber risks and assessing their cybersecurity...more

Federal Agencies Issue Final Rule on Standards for Appraisal Management Companies

The CFPB along with five other federal agencies have issued a final rule that establishes minimum state registration and substantive requirements for appraisal management companies (AMCs), as required by Section 1473 of the...more

FFIEC and CFPB Announce Updates To Web-Based HMDA Database And Tools

On September 22, the FFIEC announced an update to its online database for analyzing HMDA data and the CFPB announced updates to the agency’s corresponding HMDA tools. Originally launched in September 2013, the tool focuses on...more

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

In This Issue: - Recent Cases ..RESPA ..FDCPA ..TCPA ..FCCPA & FDCPA ..TILA - In The News ..CFPB to Begin Collecting Complaints Regarding Prepaid Cards ..CFPB Proposes Letting...more

CFPB and federal banking regulators increase focus on cybersecurity

As part of their increased focus on cybersecurity, the CFPB and federal banking are taking steps to raise financial institutions’ awareness about the need for preparedness. On June 24, 2014, the Federal Financial Institutions...more

Digital Commerce & Payments Update

In this Issue: - Insights & Trends ..The Future of Regulation in the Digital Economy - Virtual Currency ..GAO Urges CFPB Participation In Virtual Currency Working Groups ..Trade Group White Paper...more

FFIEC Establishes Cybersecurity Web Page and Announces Commencement of Cybersecurity Assessment Program of Community Banks

The Federal Financial Institutions Examination Council (the “FFIEC”) announced that it had established a web page on cybersecurity (the “Web Page”), which is designed to serve as a central repository for current and future...more

It May Be Time To Update That Social Media Policy: FFIEC Releases Social Media Guidance

On December 11, 2013, the Federal Financial Institutions Examination Council (FFIEC) released final supervisory guidance entitled "Social Media: Consumer Compliance Risk Management Guidance" (the Guidance). ...more

FFIEC Issues Joint Statements on DDoS Cyber-Attacks and Cyber-Attacks on ATM and Card Authorization Systems

On April 2, 2014 the members of the Federal Financial Institutions Examination Council (“FFIEC”) issued two joint statements: the first joint statement regards distributed denial-of-service (“DDoS”) attacks, and the second...more

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