Nonbank Firms

News & Analysis as of

Washington Amends Provisions Impacting Non-Depository Institutions

Recently, the state of Washington enacted SB 6134, which amends numerous provisions related to the supervision of non-depository institutions. The bill clarifies the statute of limitations applicable to certain violations by...more

Proposed Narrowing of Licensing Exemption under California Finance Lenders Law

The California Department of Business Oversight (“CDBO”) has proposed to narrow a long-standing interpretation of a statutory licensing exemption for certain lenders under the California Finance Lenders Law (“CFLL”)1. The...more

New York Financial Services Regulator Urges More Enforcement Against Individuals, Reaffirms Focus On Nonbank Mortgage Servicers

On March 19, New York State Department of Financial Services (DFS) Superintendent Benjamin Lawsky called on banking regulators to assess whether they are doing enough, particularly with regard to enforcement, to deter or...more

Congresswoman Urges OCC to Scrutinize Mortgage Servicing Rights Sales to Nonbank Servicers

Congresswoman Maxine Waters, who serves as the ranking member on the House of Representatives Committee on Financial Services, sent a letter to the Office of the Comptroller of the Currency and the Office of Mortgage...more

CFPB Continues Respa Enforcement With Action Against Nonbank Lender

On February 24, the CFPB announced that a nonbank mortgage lender agreed to pay an $83,000 penalty to resolve violations of RESPA’s Section 8. The lender primarily offers loss-mitigation refinance mortgage loans to distressed...more

Systemic Risk and Asset Management: Progressing from Ignorance to Confusion

Early this year, the Financial Stability Board (FSB) and the International Organization of Securities Commissions (IOSCO) issued a Consultative Document regarding Assessment Methodologies for Identifying Non-Bank Non-Insurer...more

House Passes Bill to Increase Shareholder Count Thresholds Triggering Securities Exchange Act Registration/Deregistration...

On January 14, 2014, the House of Representatives passed H.R. 801, the Holding Company Registration Threshold Equalization Act of 2013 (the “Act”), which would increase the number of shareholders that trigger registration and...more

CFPB Proposes To Regulate Large International Money Transfer Providers

On January 23, 2014, the Consumer Financial Protection Bureau (“CFPB”) issued a proposed rule that would extend its regulatory authority to certain nonbank international money transfer providers....more

CFPB Proposes To Supervise Larger Nonbank International Money Transmitters

On January 23, the CFPB proposed a rule that would allow the agency to supervise nonbank “larger participants” in the international money transfer market. The proposed rule defines “larger participant” to include any entity...more

CFPB Proposes New “Larger Participants” Rule for Non-Bank International Money Transmitters

The Consumer Financial Protection Bureau (CFPB) has proposed a new rule to define “larger participants” of the market for non-bank international money transfers. Comments to the proposed rule will be accepted by the CFPB for...more

OCC Proposes Formal “Heightened Expectations” For Large Banks, Other Complex Institutions

On January 16, the OCC released proposed guidelines to establish “heightened expectations” for large banks—those with $50 billion or more in total consolidated assets—and any other institution the OCC deems to be complex or...more

The CFPB Proposes to Supervise Nonbanks that Perform One Million or More International Money Transfers Per Year

On January 23, 2014, the Consumer Financial Protection Bureau (CFPB) proposed a rule whereby the definition of “larger participants” will be expanded to include nonbanks that perform one million or more international money...more

CFPB Proposes Definition of Larger Participants for the International Money Transfer Market

On January 23, 2014, the Consumer Financial Protection Bureau (“CFPB”) issued a proposed rule that would define which nonbank covered persons would be designated “larger participants” for purposes of the international money...more

CFPB issues proposal to supervise “larger participant” international money transfer providers

We had been expecting the CFPB’s next “larger participant” proposal to be a rule for the auto finance market. Instead, the CFPB issued a proposed rule yesterday that would allow it to supervise nonbank international money...more

Federal Financial Regulatory Agencies Poised to Implement Diversity Standards

Acting under a little-analyzed provision of the Dodd-Frank Act, six federal financial regulatory agencies recently published-joint proposed standards for assessing the diversity policies and practices of the institutions they...more

FSB and IOSCO to Consider Standards for Treating Investment Funds and Asset Managers as Global Systemically Important Financial...

The Financial Stability Board (FSB), in consultation with the International Organization of Securities Commissions (IOSCO), issued “Assessment Methodologies for Identifying Non-Bank Non-Insurer Global Systemically Important...more

CFPB 2014 Regulatory Outlook: Nonbanks

In this presentation: •Welcome •A look back at 2013 •Enforcement Actions: - Who’s at risk and what to expect •Nonbank Supervision and Examination: - Lessons learned and which markets are...more

CFPB and State Regulators Take Enforcement Action for Alleged UDAAP Violations

The CFPB announced an enforcement action against a nonbank mortgage lender and its mortgage servicer alleging the companies engaged in unfair, deceptive and abusive acts or practices in violation of the Consumer Financial...more

Covered Funds Aspects of the Volcker Rule – Frequently Asked Questions

The Federal Reserve Board, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, and the Securities and Exchange Commission (the "SEC") issued a final rule, and the Commodity Futures...more

FFIEC Issues Guidance Concerning Applicability of Federal Consumer Protection and Compliance Laws, Regulations and Policies to...

On December 11, 2013, the Federal Financial Institutions Examination Council (the “FFIEC”), on behalf of its members (the OCC, FRB, FDIC, NCUA and the Consumer Financial Protection Bureau (“CFPB”)), released final guidance...more

Summary of the Volcker Rule

On December 10, 2013, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the Securities and Exchange Commission, and the Commodity...more

Social Media: Consumer Compliance Risk Management Guidance

On December 11, 2013, the Federal Financial Institutions Examination Council (FFIEC) released final guidance (“Guidance”) on the applicability of consumer protection and compliance laws, regulations, and policies to...more

CFPB Issues Fall 2013 Regulatory Agenda

On December 3, 2013, the Consumer Financial Protection Bureau (“CFPB”) released its semi-annual update to its rulemaking agenda. The fall 2013 agenda covers rulemaking that the CFPB is continuing to work that are mandated by...more

Orrick's Financial Industry Week in Review - December 10, 2013

Council of EU Publishes UK Issues Paper on MLD4 - On November 24, the Council of the European Union published a note (dated November 8, 2013) from the Council Presidency to Council Delegations which includes a UK...more

CFPB Issues a Rule to Oversee Nonbank Student Loan Servicers

On December 3, the CFPB issued a rule that allows it to supervise certain nonbank student loan servicers. The CFPB estimates that it will have authority to supervise the seven largest student loan servicers....more

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