Nonbank Firms

News & Analysis as of

CFPB Identifies Deceptive, Abusive Practices in the Marketing of Credit Card Promotional APR Offers

The Consumer Financial Protection Bureau recently issued a bulletin (CFPB Bulletin 2014-02) warning credit card issuers to avoid potentially deceptive and abusive practices in connection with the marketing of credit card...more

CFPB Proposes Expanded Auto Lenders Regulation

The Consumer Financial Protection Bureau’s (CFPB) recent proposal to exercise its authority under the Dodd-Frank Act to supervise large nonbank automobile lenders may have finance companies working to enforce...more

Bank Regulator Eyes Insurer Capital

The Federal Reserve Board (FRB) has begun a process that will lead to the imposition of new capital requirements on some large insurance companies. Pursuant to Section 171 of the Dodd-Frank Act, the FRB gained authority to...more

In The Cross-Hairs? Protecting Your Company Against Consumer Financial Protection Bureau Investigations and Investors' Mortgage... [Video]

Watch an in-depth webinar presented by Litigation Partner Philip R. Stein, about the Consumer Financial Protection Bureau's attempts to expand its jurisdiction and authority over consumer finance companies and financial...more

Banking & Financial Services E-Note - September 2014

In This Issue: - CFPB to Regulate Nonbank Institutions That Fund Auto Loans - DOJ Suggests Banks Turn In Employees to Avoid Criminal Charges - Regulators Requiring Banks to Carry Higher Capital...more

Start Your Compliance Engines: CFPB Proposes Rule to Supervise Larger Nonbank Auto Finance Companies

The Consumer Financial Protection Bureau (“CFPB” or “Bureau”) issued a proposed rule on September 17, 2014, that would empower the Bureau to supervise certain larger nonbank automobile finance companies. The CFPB proposed the...more

Defense Department Proposes Expansion of Military Lending Act Regulations

The Department of Defense (DoD) has issued a proposal to revise and significantly expand the coverage of its rule implementing the Military Lending Act (MLA). The proposed revisions would limit interest charged to...more

CFPB to Regulate Larger Nonbank Auto Lenders

The CFPB is proposing to oversee larger nonbank auto finance companies for the first time at the federal level. Currently, the Bureau supervises large banks making auto loans, but not nonbank auto finance companies. ...more

CFPB Finalizes Rule To Oversee Larger Nonbank International Money Transfer Providers

On September 12, the CFPB finalized a rule that allows it to supervise larger participants in the international money transfer market. In particular, this rule, which finalizes the proposed rule the CFPB issued in January...more

Legal Alert: CFPB Proposes to Examine and Directly Supervise Nonbank Auto Lenders

On September 17, the Consumer Financial Protection Bureau (CFPB) proposed to make nonbank automobile lenders subject to the examination and direct supervision of the Bureau. The proposed rule can be found here. Under the...more

CFPB Offers More Details On Plans To Supervise Auto Finance Market

On September 17, the CFPB released new information about its plans to supervise and enforce auto finance companies’ compliance with consumer financial laws, including fair lending laws. As it indicated it would earlier this...more

CFPB Proposes Rule To Supervise Nonbank Auto Finance Companies

The Consumer Financial Protection Bureau has issued a proposal to supervise nonbank companies that qualify as “larger participants of a market for automobile financing.” Comments on the proposal will be due 60 days after the...more

CFPB finalizes rule to supervise larger participant international money transfer providers

The CFPB has issued a final rule that will allow it to supervise nonbank international money transfer providers that qualify as “larger participants” in the international money transfer market. Consistent with the proposed...more

New Larger Participant Rule Enhances Supervision of Remittance Transfer Rule Requirements

The Consumer Financial Protection Bureau recently finalized a larger participant rule for nonbank international money transfer providers and left it largely unchanged from the rule as originally proposed in January. The new...more

Financial Regulatory Developments Focus - September 2014 #3

In this issue: - Derivatives - Consumer Protection - Enforcement - People - Events - Excerpt from Derivatives: CFTC Issues No-Action Relief for Qualifying Swaps Trading...more

FIO Focus, Issue No. 60

FSOC Issues Proposed Determination of SIFI Designation for MetLife - On September 4, 2014, the Financial Stability Oversight Council (FSOC) issued a “proposed determination” that Metropolitan Life Insurance Company...more

California Creates Exemption from Finance Lenders Law for Certain Nonprofits

The state of California amended its Finance Lenders Law in an effort to help individuals obtain access to affordable, credit-building small dollar loans. The new law makes exempt from Finance Lenders Law a nonprofit...more

House Passes Bill to Fix Privilege Waiver Problem for Nonbanks

A bill (H.R. 5062) recently passed by the House of Representatives would amend the Consumer Financial Protection Act (the CFPA), which is Title X of the Dodd-Frank legislation, to provide protection against waiver of state...more

Blurred Lines

Mobile payments are taking off, and by 2017, consumers worldwide are likely to be using the technology to spend $700 billion or more annually, according to Forrester Research. But as technology companies look for ways to...more

HUD Announces Disability Income Fair Housing Conciliation Agreement

On August 13, HUD announced that a nonbank mortgage lender agreed to pay $104,000 to resolve allegations that the lender’s underwriting practices resulted in discrimination against mortgage applicants who rely on disability...more

CFPB Fines Online Mortgage Company And Its Owner For Alleged Deceptive Rate Advertising

On August 12, the CFPB announced a consent order with a nonbank mortgage lender, its affiliated appraisal management company (AMC), and the individual owner of both companies to resolve allegations that the lender deceptively...more

CFPB Opens Door for Prepaid Card, Nonbank Product Complaints

Expanding its collection of consumer complaints, the Consumer Financial Protection Bureau (CFPB) announced that it will now accept complaints regarding prepaid cards – including gift cards, benefit cards, and general purpose...more

Senate Passes Nonbank Remittance Supervision Bill

On August 1, the U.S. Senate passed by unanimous consent H.R. 4386, which will permit FinCEN, in fulfilling its responsibility to supervise registered money services businesses (MSBs), to rely on state agency examinations of...more

House Passes Nonbank Examination Bill; House Committee Approves Mortgage-Related Bills

On July 29, the U.S. House of Representatives passed by voice voteH.R. 5062, a bipartisan bill that would amend the Consumer Financial Protection Act with respect to the supervision of nondepository institutions, to require...more

FHFA OIG Assesses Risks From Smaller Lenders And Nonbank Mortgage Companies

On July 17, the FHFA Office of Inspector General (OIG) published a report on risks to Fannie Mae and Freddie Mac (the Enterprises) related to purchasing mortgages from smaller lenders and nonbank mortgage companies....more

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