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OCC Issues New Third-Party Risk Management Guidance

On October 30, 2013, the Office of the Comptroller of the Currency (OCC) issued new guidance on risks presented by third-party relationships, entitled “Third-Party Relationships: Risk Management Guidance” (“2013 Bulletin”)....more

CFPB Signals Additional Concerns about Consumer Credit Card Market with Report on CARD Act

Yesterday, the Consumer Financial Protection Bureau (“CFPB”) released the “CARD Act Report,” a report summarizing the CFPB’s views on the impact of the Credit Card Accountability Responsibility and Disclosure Act of 2009...more

The Consumer Financial Protection Bureau: Measuring the Progress of a New Agency

In This Issue: Executive Summary; Introduction; Focus of Consumer Protection Task Force; History of the CFPB; Rule-Making; Examinations and Data; Consumer Relations; The Scope of CFPB Authority; Transparency; CFPB...more

Inter-Governmental Task Force Recommends Extending Anti-Money Laundering Measures to Telecoms, Software Companies and Other...

The Financial Action Task Force (“FATF”) recently released a white paper entitled “Guidance for a Risk Based-Approach: Prepaid Cards, Mobile Payments and Internet-based Payment Services” (“Guidance”). The Guidance contains...more

Senators Request CFPB Issue Guidance and Rulemakings, Bring Enforcement Actions Relating to Payroll Card Programs

Last week, 16 Democratic Senators sent a letter on regulation of payroll cards to Consumer Financial Protection Bureau (“CFPB”) Director Richard Cordray and Department of Labor (“DOL”) Acting Secretary Seth Harris. The letter...more

Bitcoin Receives Cease and Desist Order Evidencing Increased Regulatory Scrutiny of Virtual Currency

On May 30, 2013, the California Department of Financial Institutions (“CADFI”) issued a cease and desist letter to Bitcoin Foundation, a not-for-profit organization established to standardize, protect, and promote the use and...more

Mobile Apps Bill Introduced in the House of Representatives

Lawmakers in Washington, D.C., continue to show interest in understanding and developing regulatory proposals relating to mobile apps. The interest appears to be driven, at least in part, by policymakers’ concerns about...more

CFPB Uses Novel Interpretation, Increases Compliance Burden for Gift Card Issuers Through its First Preemption Determination

On April 19, 2013, the Consumer Financial Protection Bureau (“CFPB”) announced it was making a determination to preempt a provision of Tennessee unclaimed property law that it deemed inconsistent with the federal Electronic...more

Financial Services Report - Spring 2013

Editor’s Note - This is a dignified law firm newsletter, not like the “Brand X” versions. You won’t find pandering, attention-grabbing stories about Justin Bieber, Kim Kardashian, Ashton Kutcher, Prince William, or...more

D.C. Circuit Hands the CFPB a Setback?

At the end of last week, the U.S. Court of Appeals for the District of Columbia Circuit issued its decision in Noel Canning v. National Labor Relations Board, holding that President Obama’s recess appointments to the National...more

Dodd-Frank Implementation: Navigating the Road Ahead

Table of Contents: Introduction; Financial Stability Reform; Resolution Planning; Agencies and Agency Oversight Reform; Securitization Reform; Derivatives Regulation; Investor Protection Reform; Credit Rating Agency...more

CFPB Warning and Bulletin for Nationwide Specialty CRAs

The Consumer Financial Protection Bureau (“CFPB”) has sent warning letters to several nationwide specialty consumer reporting agencies (“CRAs”), notifying the CRAs that the CFPB believes that the CRAs are not complying with...more

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