Consumer Finance Monitor Podcast Episode: Perspectives on Counseling on the Creation of Consumer Finance Products, with Guest Joseph Schuster, Managing Director and Senior Counsel, Goldman Sachs
AI: Impact and Use in the Financial Services Industry – Crossover Episode with Regulatory Oversight Podcast - The Consumer Finance Podcast
The Significance of Operational Technology in Cyber Insurance Underwriting – Part 2
The Downstream Impact of Ransomware on Cyber Insurance Underwriting – Part 1
Has the SPAC Bubble Burst? Part 2: The SEC’s New Rules
Has the SPAC Bubble Burst? Lessons Learned From the Early Days of SPAC Mania
Smoother Sailing or Choppy Waters: What Lies Ahead for the 2022 D&O Market?
D&O in Brazil and Latin America
Regan Miller, RPLU on Cyber Risk
The Solvency Capital Requirement (SCR) is designed to protect policyholders by helping ensure that insurers can survive difficult periods and pay claims as they fall due. It prescribes a specific level of capital that an...more
Traditional credit underwriting methods, which are generally based on credit reports, have not always successfully captured the full picture of a borrower’s ability to repay. It is estimated that more than 45 million US...more
Selected U.S. Privacy and Cyber Updates - NYDFS Releases Circular Letter on Use of AI in Insurance Underwriting and Pricing - On January 17, 2024, the New York State Department of Financial Services (NYDFS) issued a proposed...more
New York’s Department of Financial Services releases proposed guidance on AI and other data sources in insurance underwriting and pricing — and you’ll note plenty of influence from Colorado’s governance regulation and the...more
The New York State Department of Financial Services (“DFS”) has entered its voice regarding the use of artificial intelligence (“AI”) by insurers by issuing for public comment a proposed circular letter addressing the use of...more
The Ontario Securities Commission (“OSC”) recently made proposed OSC Rule 33-509 Exemption from Underwriting Conflicts Disclosure Requirements (the “Rule”) to provide a permanent exemption in Ontario from the underwriting...more
On September 15, 2023, the Consumer Financial Protection Bureau (CFPB) published an outline of expansive rulemaking proposals to modernize the coverage of the Fair Credit Reporting Act (FCRA) to include data brokers, data...more
On July 27, the Consumer Financial Protection Bureau (CFPB) released a new blog post, positing that cashflow data, broadly defined as the various inflows, outflows, and accumulated amounts in a consumer’s checking and savings...more
On May 22, Freddie Mac announced new capabilities allowing lenders to use a borrower’s digital paystub data when assessing income paid through direct deposit. Lenders will be able to access the enhancements to Freddie’s...more
Financial services companies are using AI to assist with many business processes, including underwriting decisions, consumer credit approval, servicing and collections, loss mitigation programs, customer interaction on...more
On January 2, the New York City (NYC) Comptroller, Brad Lander, the NYC Employees’ Retirement System, the NYC Teachers’ Retirement System, and the NYC Board of Education Retirement System, announced that they had submitted...more
The Bank of Israel recently published a draft directive on proper banking management. It details various provisions in favor of changing the conduct patterns of consumer credit providers toward their clients, both from the...more
On November 30, 2020, the Consumer Financial Protection Bureau (CFPB) granted a no-action letter to an online loan marketplace company for its artificial intelligence (AI) loan origination and underwriting platform. ...more
In the News. The Board of Governors of the Federal Reserve System (Federal Reserve) proposed rules to modernize the regulations that implement the Community Reinvestment Act (CRA); the Conference of State Bank Supervisors...more
The CFPB recently updated its Home Mortgage Disclosure Act (HMDA) FAQs to add two items regarding multiple data points....more
The Consumer Financial Protection Bureau (CFPB) issued a final rule on July 7, 2020 rescinding the mandatory ability to repay underwriting provisions on small dollar loans that it had previously announced under 12 C.F.R. §...more
In a new era of double-digit unemployment resulting from the COVID-19 pandemic, it may be tough for a mortgage lender to predict the amount and stability of someone’s income in order to determine qualification for a home...more
As the U.S. wrestles with COVID-19, federal banking agencies are encouraging banks and credit unions to make responsible small-dollar loans to consumers and small businesses. Partnering with a financial technology company...more
Mortgage loan brokers, correspondents and loan originators (“Originators”) who survived (or, in many cases, are still dealing with) the onslaught of “repurchase/indemnification” claims asserted by loan aggregators and...more
Focus areas included FCRA, Fair Lending, ancillary fees and services (such as lender placed flood insurance), TCPA, privacy and data security and other topics. Consumer Financial Protection Bureau’s Director Kathleen...more
On February 20, the Consumer Financial Protection Bureau (CFPB), South Carolina Department of Consumer Affairs, and Arkansas Attorney General’s Office announced? that they had filed a lawsuit in the U.S. District Court for...more
When the federal Consumer Financial Protection Bureau (“CFPB”) last summer issued its Advance Notice of Proposed Rule Making (“ANPR”) to revise the definition of a “Qualified Mortgage” (“QM”) under the Dodd-Frank Act’s...more
The OCC announced yesterday that it’s bringing enforcement actions against five former Wells Fargo bank executives as part of their alleged roles in the bank’s sales practices scandal. The agency further revealed that it’s...more
The NYSE proposed in November changes to its listing standards to allow “primary” share offerings through a direct listing. To date, direct listings have been in the form of stockholder share resales (a “secondary offering”)...more
On Tuesday, December 3, 2019, U.S. federal banking regulators issued an interagency statement supporting the evaluation of alternative data when assessing consumers’ creditworthiness. Recognizing that the use of alternative...more