Most legal entities like corporations have officers and directors who, together, run the business. Directors sit on the board of directors and collectively govern and oversee the entity. In contrast, officers generally...more
On February 8, 2024, after nearly a decade of litigation, the CFPB announced a final settlement for a total of $12 million with a Foreclosure Relief Company and four individual attorneys. The settlement resolves litigation...more
Regulatory Developments - FinCEN Issues NPRM Regarding Access to Beneficial Ownership Information and Related Safeguards - On December 15, FinCEN issued a Notice of Proposed Rulemaking (NPRM) that would implement...more
On December 22, just before many of us may have started turning to our holiday breaks, the Federal Reserve Board (“FRB”), Federal Deposit Insurance Corporation (“FDIC”) and Office of the Comptroller of the Currency (“OCC”)...more
On December 22, the Federal Reserve Board, FDIC, and OCC extended Regulation O relief for certain investment fund-controlled companies. ...more
In a decision issued earlier this summer, the U.S. Court of Appeals for the Seventh Circuit vacated the district court’s order awarding restitution, mandating civil penalties, and issuing an injunction in an action brought by...more
In this Issue. The U.S. Securities and Exchange Commission (SEC) was very active this week, having (i) issued no-action relief allowing registered funds to engage in self-custody of interests in loans that are originated,...more
The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (Federal Banking Agencies) on December 27, 2019 provided temporary relief from...more
On September 6, 2019, the Bureau filed a complaint in federal court in the Central District of California against Certified Forensic Loan Auditors, LLC (CFLA) and Andrew Lehman (Lehman) in connection with their offering,...more
On Monday, the U.S. Supreme Court denied the petition for certiorari in CFPB v. Chance Edward Gordon, a case filed by the CFPB in 2012 that alleged the defendant had duped consumers by falsely promising loan modifications in...more
Two enforcement actions filed by the CFPB recently went to trial in federal district court. One of the cases was filed by the CFPB in July 2014 in a Wisconsin federal district court against two law firms and four of the...more
Since it was filed in a California federal court in July 2012, we have been following CFPB v. Chance Edward Gordon, a case in which the CFPB alleged that an attorney duped consumers by falsely promising loan modifications in...more
The U.S. District Court for the Western District of Wisconsin ruled on July 20, 2016, that the Consumer Financial Protection Bureau (CFPB) may hold the owners of two law firms offering debt relief services liable for alleged...more
The Ninth Circuit recently considered arguments relating to an enforcement action brought by the Consumer Financial Protection Bureau (CFPB) against a California attorney who was offering loan modification services. The CFPB...more
Since it was filed in a California federal court in July 2012, we have been following Consumer Financial Protection Bureau (CFPB) v. Chance Edward Gordon, a case in which the CFPB alleged that an attorney duped consumers by...more
The CFPB announced that, together with the Florida AG, it has obtained judgments against several Florida companies and their individual operators who were charged in a complaint filed in a Florida federal court with using...more
It is difficult (if not impossible) for a community bank to stay current on all the new rules spawned by Dodd-Frank. (For example, the rules promulgated under Dodd-Frank could fill approximately 32 copies of the great but...more