Risk Management Consumer Financial Protection Bureau

News & Analysis as of

FSOC on Fintech Risks, Cybersecurity Vigilance

An annual report from the Financial Stability Oversight Council (FSOC) recently focused on the risks presented by the burgeoning fintech industry as well as the continuing "pressing concern" of cyber threats and...more

Financial Services Weekly News - July 2016 #2

Regulatory Developments - Client Alert: Volcker Rule Conformance Period for Legacy Covered Fund Activities Extended One Year - On July 7, the Board of Governors of the Federal Reserve System announced that it has...more

Nutter Bank Report, June 2016

The Nutter Bank Report is a monthly publication of the firm's Banking and Financial Services Group. Headlines 1. Agencies Publish Proposed Rule to Limit Incentive-Based Compensation Arrangements 2. Guidance on New...more

Orrick's Financial Industry Week in Review

SEC Adopts Trade Acknowledgment and Verification Rules for Security-Based Swap Transactions - On June 8, 2016, the Securities and Exchange Commission publicized the implementation of "rules that will establish timely and...more

Top 10 Financial Institution Considerations for 2016: #6 – Vendor Risk Management

In our initial article announcing our top 10 considerations for financial institutions in 2016, our sixth consideration was vendor risk management in 2016. Third party (vendor) risk management has consistently been among the...more

OCC Issues White Paper on "Responsible Innovation"

On March 31, 2016, the Office of the Comptroller of the Currency (OCC) issued a white paper on the growing intersection between financial services and technology. The OCC stated that "[w]hile banks continue to innovate, rapid...more

OCC White Paper Promotes Framework for Supporting Responsible Innovation

Following the trend of federal agency interest in fostering (and potentially regulating) innovation in the field of financial technology (FinTech), the Office of the Comptroller of the Currency (OCC) released the white paper...more

ICYMI: Financial Services Risk Summit

On March 3, 2016, the BakerHostetler Financial Services industry team held its inaugural Financial Services Risk Summit. The speakers and panels addressed several key areas affecting the financial services sector: regulatory...more

OCC Issues FinTech White Paper Indicating Openness to 'Responsible Innovation'

On March 31, 2016, the Office of the Comptroller of the Currency (“OCC”) issued its much-anticipated white paper on the growing intersection between financial services and technology, or “FinTech.” In his prepared remarks at...more

FTC Highlights FDCPA Risks for Debt Collectors Using Social Media, Texts

The Federal Trade Commission (FTC) recently published a reminder to debt collectors of the Fair Debt Collection Practices Act (FDCPA) compliance risks that are created by the use of social media or text messages in connection...more

The Consumer Financial Protection Bureau: What Insurers Should Know

Q: When does the Consumer Financial Protection Bureau (CFPB) have authority over insurance ?companies? The federal legislation commonly known as the Dodd-Frank Wall Street Reform Act, which created the ?CFPB,...more

Dodd-Frank at 4: Where do we go from here?

Where do we go from here? As we mark another milestone in regulatory reform with the fourth anniversary of the enactment of the Dodd-Frank Act, it strikes us that although most studies required to be undertaken by the Act...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

The Equal Credit Opportunity Act – a Sword and a Shield?

The year was 1974 and, on the heels of the civil rights movement, was a time when the country maintained its heightened awareness of equality and discrimination. This was the year that the Equal Credit Opportunity Act (ECOA)...more

BNA's Banking Report: Enforcement 2013: Enforcement Actions Continue Three-Year Decline; DOJ Emerges as Major Player

Overall Trends & Outlook - From an enforcement standpoint, 2013 was another historic year in a number of important ways beyond the sheer number of cases, which were again significant. Federal banking agencies1 issued...more

Fair Servicing: Regulators Watch for Discrimination by Servicers

Federal regulators delivered that message in October 2013, reminding loan servicers that they are subject to fair lending liability and must manage their fair lending risks. The regulators’ message concerning “fair servicing”...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

OCC Issues New Risk Management Guidance For Third Party Relationships

The Office of the Comptroller of the Currency published on October 30, 2013 a new Guidance relating to risk management for third party relationships. This Guidance rescinds OCC Bulletin 2001-47, “Third-Party Relationships:...more

Orrick's Financial Industry Week in Review - August 26, 2013

European Banking Authority Publishes Responses to Consultation Paper on the Definition of Material Risk Takers for Remuneration Purposes - The European Banking Authority (EBA) published a list of responses received to...more

CFPB ready to supervise nonbanks engaged in conduct deemed risky for consumers

The CFPB has adopted its long-awaited final rule setting forth the procedures it will use to supervise nonbanks engaged in conduct that poses risks to consumers. The final rule will be effective 30 days after its publication...more

FFIEC Proposes Supervisory Guidance for Financial Institutions Using Social Media

The Federal Financial Institutions Examination Council (the “FFIEC”) has proposed supervisory guidance addressing the applicability of federal consumer protection and compliance laws, regulations, and policies to activities...more

Proposed FFIEC Guidance on Financial Institution Social Media Use

The Federal Financial Institutions Examination Council (FFIEC) released for comment on January 17 its proposed Social Media: Consumer Compliance Risk Management Guidance. There is a 60-day comment period. The purpose of the...more

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