The Financial Institutions Reform, Recovery and Enforcement Act of 1989 (“FIRREA”) is a powerful tool in the prosecutorial arsenal. Due to its long statute of limitations, expansive penalty provision, and low civil burden of...more
3/19/2021
/ CARES Act ,
Civil Monetary Penalty ,
CMBS ,
Coronavirus/COVID-19 ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Financial Institutions ,
FIRREA ,
Fraud ,
Paycheck Protection Program (PPP) ,
SBA ,
U.S. Treasury
With the change of administration in Washington, the Consumer Financial Protection Bureau (the “CFPB” or “Bureau”) is widely expected to assume a posture of aggressive enforcement of consumer protection laws. One area that we...more
1/15/2021
/ CARES Act ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Dodd-Frank ,
Enforcement Actions ,
Financial Institutions ,
Interest Rates ,
Payday Lending Rule ,
Title X
In October of last year, we wrote about the challenges faced by virtual currency businesses in complying with the Travel Rule following new guidance from the Financial Action Task Force (FATF) and the Financial Crimes...more
11/5/2020
/ Bank Secrecy Act ,
Compliance ,
Cryptocurrency ,
Department of Justice (DOJ) ,
FATF ,
Federal Reserve ,
Financial Institutions ,
FinCEN ,
Proposed Rules ,
Suspicious Activity Reports (SARs) ,
Travel Rule ,
Uniform Commercial Code (UCC) ,
Virtual Currency ,
Wire Transfers
The Fair Housing Act (“FHA”), enacted more than fifty years ago, prohibits discriminatory practices in housing. The FHA makes it illegal to “make unavailable or deny . . . a dwelling to any person” or “discriminate against...more
6/20/2019
/ Algorithms ,
Anti-Discrimination Policies ,
Artificial Intelligence ,
Fair Housing Act (FHA) ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
Financial Services Industry ,
HUD ,
Lenders ,
Popular ,
Screening Procedures ,
Technology Sector ,
UDAP