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Risk Management Consumer Financial Protection Bureau (CFPB) Office of the Comptroller of the Currency

Cadwalader, Wickersham & Taft LLP

Summer Regulatory Round-Up | July 2024

The banking regulators have not yet gone out on vacation, as demonstrated by this grab-bag of announcements, speeches, rules and guidance: Acting Comptroller of the Office of the Comptroller of the Currency (OCC),...more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - March 2024 # 3

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Jenner & Block

Client Alert: Buy Now, Pay Later: A Roadmap for Providers as Regulators Continue to Increase Scrutiny

Jenner & Block on

Point-of-sale financing arrangements payable in four or fewer interest-free installments, known as buy now, pay later (BNPL) arrangements, have soared since their initial breakthrough during the pandemic. Unlike conventional...more

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - February 2024 - 3

Editor's Note: The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically...more

Spilman Thomas & Battle, PLLC

Promissory Notes - Banking & Finance Insights: V 4, Issue 1, January 2024

OCC Issues Guidance on ‘Buy Now, Pay Later’ Lending - “The guidance notes that banks should maintain underwriting, repayment terms, pricing, and safeguards that minimize adverse customer outcomes and should ensure that...more

Husch Blackwell LLP

The OCC Issues Bulletin Addressing Buy Now, Pay Later Lending

Husch Blackwell LLP on

What seems to have become a perennial topic for regulators, the Office of the Comptroller of the Currency (OCC) recently released OCC Bulletin 2023-37 to assist national banks and federal savings banks with effectively...more

Dechert LLP

Proposed Rule on Quality Control Standards for Automated Valuation Models: Comments Closed and Now What?

Dechert LLP on

The proposed rule, if adopted, would apply to mortgage originators and issuers of mortgage-backed securitizations that rely on automated valuation models (“AVMs”) to determine the value of real estate collateral. The...more

Snell & Wilmer

Climate-Related Financial Risk Management Final Interagency Guidance Rules Issued – Now What’s Next?

Snell & Wilmer on

On October 24, 2023, the Federal Reserve (Fed), Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller of the Currency (OCC) issued the joint agency climate-related financial risk management guidance for...more

McGlinchey Stafford

Deep Dive into Payments: Q&A on Bank Partnership Considerations

McGlinchey Stafford on

But upon closer consideration, there is an interplay between a bank partner program and the Electronic Fund Transfer Act (EFTA) as implemented by Regulation E, particularly when it comes to timeframes for disputes, liable...more

Goodwin

Agencies Issue Final Guidance on Third-Party Risk Management

Goodwin on

Agencies Issue Final Guidance on Third-Party Risk Management - On June 6, the Federal Reserve, FDIC, and OCC issued final joint guidance (the Guidance) pertaining to banking organizations’ risk management of third-party...more

Goodwin

Overdraft Protection Programs: Risk Management Practices

Goodwin on

Regulatory Developments - Overdraft Protection Programs: Risk Management Practices - On April 26, the OCC issued guidance in OCC Bulletin 2013-12, “Overdraft Protection Programs: Risk Management Practices,” to...more

Goodwin

Agencies Issue Joint Statement on Liquidity Risks Resulting from Crypto-Asset Market Vulnerabilities

Goodwin on

Regulatory Developments - Agencies Issue Joint Statement on Liquidity Risks Resulting from Crypto-Asset Market Vulnerabilities - On February 23, the Federal Reserve, FDIC and OCC (the Agencies) issued a “Joint...more

Goodwin

Federal Reserve Invites Public Comment on Proposed Principles for Large Banking Organizations to Manage Climate-Related Financial...

Goodwin on

Regulatory Developments - Federal Reserve Invites Public Comment on Proposed Principles for Large Banking Organizations to Manage Climate-Related Financial Risks - On December 2, the Federal Reserve announced that it...more

Goodwin

CFPB Launches New Initiative Focused on Rural Communities

Goodwin on

In This Issue. The Consumer Financial Protection Bureau (CFPB) announced a new initiative focused on financial issues faced by rural communities and also updated its examination procedures to cover unfair discrimination; the...more

Goodwin

FinCEN Warns Against Evasion of Russian Sanctions

Goodwin on

In this Issue. The Financial Crimes Enforcement Network (FinCEN) published an alert warning financial institutions of possible efforts to evade U.S.-imposed sanctions on Russia and Belarus; the U.S. Department of the Treasury...more

Goodwin

SEC Proposes Changes to Private Fund Regulation

Goodwin on

In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed changes to private fund regulation; the Office of the Comptroller of the Currency (OCC) succeeded in validating its “valid-when-made” rulemaking; the...more

Goodwin

SEC Proposes New Round of Money Market Fund Reforms

Goodwin on

In This Issue. The U.S. Securities and Exchange Commission (SEC) voted to propose money market fund reforms; the SEC also proposed amendments to Rule 10b5-1 trading plans and to modernize and improve share repurchase...more

Goodwin

SEC Publishes Observations From its Registered Investment Company Initiatives

Goodwin on

In this Issue. The U.S. Securities and Exchange Commission’s (SEC) Division of Examinations recently published a risk alert spotlighting observations from its “RIC Initiatives”; the Federal Financial Institutions Examination...more

Goodwin

CFPB Withdraws Proposal to Delay Debt Collection Final Rules

Goodwin on

In This Issue. The Consumer Financial Protection Bureau (CFPB) withdrew its proposal to delay the Debt Collection Final Rules; the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance...more

Perkins Coie

Fintech Legal Report - August 2021

Perkins Coie on

Senators Inquire about CFPB’s Fintech Agenda - On July 27, 2021, Senator Sherrod Brown, the Chairman of the U.S. Senate Committee on Banking, Housing, and Urban Affairs, sent a letter to the Consumer Financial Protection...more

Sheppard Mullin Richter & Hampton LLP

FFIEC Issues Updated Guidance on Authentication and Access to Financial Institution Services and Systems

On August 11, the Federal Financial Institutions Examinations Council (FFIEC) issued new guidance, providing examples of effective authentication and access risk management principles and practices for financial institutions....more

Holland & Knight LLP

CFPB Proposes Settlement with Debt Collector for Failing to Investigate Identity Theft Reports

Holland & Knight LLP on

With the ongoing COVID-19 pandemic, credit card companies may face increased scrutiny, as Consumer Financial Protection Bureau (CFPB) Acting Director Dave Uejio recently stated that "credit reports play a huge role in...more

Sheppard Mullin Richter & Hampton LLP

Federal Agencies Request Comments on Risk Management Guidance for Third-Party Relationships

On July 13, the Federal Reserve, FDIC, and OCC proposed risk management guidance to help banking organizations manage risks related to third-party relationships, including relationships with vendors, FinTech companies,...more

Ballard Spahr LLP

Federal banking agencies issued proposed guidance on risk management for third-party relationships

Ballard Spahr LLP on

The Federal Reserve, FDIC, and OCC have released proposed guidance for banking organizations on managing risks associated with third-party relationships, including relationships with financial technology-focused entities such...more

Wiley Rein LLP

Wiley Consumer Protection Download (June 7, 2021)

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Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more

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