Is it just us or does March 4 — the date of our last issue — feel like a million years ago? Like you, and not necessarily in this order, we have been: doing our work; keeping up with COVID-19-related laws, guidance, and...more
7/15/2020
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Arbitration ,
Auto-Dialed Calls ,
BSA/AML ,
CARES Act ,
Consent Order ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
CRA ,
Dodd-Frank ,
E-SIGN ,
Fair Lending ,
FASB ,
FDIC ,
Federal Reserve ,
FinCEN ,
FinTech ,
HMDA ,
Interim Final Rules (IFR) ,
Money Market Mutual Fund Liquidity Facility (MMLF) ,
OCC ,
Paycheck Protection Program Lending Facility (PPPLF) ,
Popular ,
Remittance Transfer Rule ,
Request For Information ,
RESPA ,
SPVs ,
TCPA ,
Volcker Rule
The holidays came early for financial institutions when the Supreme Court agreed to hear a challenge to the constitutionality of the CFPB. We can expect fireworks in the New Year as two experienced Supreme Court practitioners...more
We start this issue with a feeling of déjà vu all over again. Decisions made during the mortgage crisis are back in the news with a powerhouse legal ruling and the Treasury’s initial thinking on how to turn back time. First,...more
9/12/2019
/ Appeals ,
Arbitration ,
BSA/AML ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Fair Credit Reporting Act (FCRA) ,
Fair Lending ,
FDIC ,
Federal Trade Commission (FTC) ,
Financial Services Industry ,
FinCEN ,
GAO ,
HUD ,
Libor ,
Money Laundering ,
No-Action Letters ,
Reporting Requirements ,
Secured Overnight Funding Rate (SOFR) ,
Securities and Exchange Commission (SEC) ,
SHIELD Act ,
TCPA ,
Volcker Rule
The fireworks have started early this year. On May 2, a federal court in New York rejected the OCC’s motion to dismiss the lawsuit brought by the NY DFS challenging the OCC’s fintech charter. The decision has something for...more
6/18/2019
/ Appeals ,
Arbitration ,
BSA/AML ,
Consumer Financial Protection Bureau (CFPB) ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
OCC ,
TCPA ,
UDAP
In between holiday shopping and merriment, we here at the Financial Services Report are pondering what’s in a name. Not much, said Shakespeare. Isaac Asimov begged to differ in a mystery story about who killed one of the...more
12/12/2018
/ Appeals ,
Arbitration ,
Auto-Dialed Calls ,
BSA/AML ,
Consumer Financial Protection Bureau (CFPB) ,
Fair Lending ,
Financial Services Industry ,
FinCEN ,
HMDA ,
Lenders ,
Mortgages ,
OCC ,
Opt-Outs ,
Payday Lending Rule ,
Privacy Laws ,
SCOTUS ,
TCPA
EDITOR’S NOTE -
So much for the lazy days of summer. It’s been a busy couple of months on both coasts. In a case of déjà vu all over again, a New York federal court found that the CFPB structure is unconstitutional and that...more
9/12/2018
/ Arbitration ,
BSA/AML ,
Consent Order ,
Consumer Financial Protection Bureau (CFPB) ,
Fair Credit Reporting Act (FCRA) ,
Fair Lending ,
Financial Services Industry ,
FinTech ,
Fixing America’s Surface Transportation Act (FAST Act) ,
Mortgages ,
OCC ,
RMBS ,
TCPA ,
U.S. Treasury ,
Volcker Rule
BELTWAY -
The Wayback Machine -
Congress passed, and on May 24, 2018, the president signed into law, the Economic Growth, Regulatory Relief, and Consumer Protection Act (S.2155). The law makes significant changes to...more
6/8/2018
/ Arbitration ,
Auto Lease ,
Banking Sector ,
BSA/AML ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Economic Growth Regulatory Relief and Consumer Protection Act ,
Fair Lending ,
FDCPA ,
FFIEC ,
FinTech ,
GAO ,
General Data Protection Regulation (GDPR) ,
HMDA ,
Securities and Exchange Commission (SEC) ,
SIFMA ,
TCPA
The 2018 Winter Olympics are over. We watched two 17-year-olds win gold medals in sports that didn’t exist when we were 17. The Garlic Girls, with nicknames from their favorite breakfasts, and the U.S. men’s team won medals...more
3/13/2018
/ Arbitration ,
BSA/AML ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Cybersecurity ,
Fair Lending ,
FDIC ,
Financial Services Industry ,
FinTech ,
Prepaid Payment Products ,
Restitution ,
TCPA ,
Vicarious Liability
EDITOR’S NOTE -
Through hurricanes, wild fires, the publication of Hillary Clinton’s book, the birth of Amal and George Clooney’s twins, and the Dodgers’ historic losing streak, Director Richard Cordray and the CFPB’s...more
9/21/2017
/ Arbitration ,
BSA/AML ,
Credit Repair Services ,
Data Breach ,
Fair Credit Reporting Act (FCRA) ,
Fair Lending ,
False Claims Act (FCA) ,
FCC ,
FinTech ,
OCC ,
Ransomware ,
RESPA ,
Spokeo v Robins ,
Standing ,
Stress Tests ,
TCPA ,
U.S. Treasury ,
Volcker Rule
EDITOR’S NOTE -
Summer blockbuster season is officially upon us. Have you seen Wonder Woman yet? What about Guardians of the Galaxy Part 2? It’s déjà vu all over again with Baywatch, Pirates of the Caribbean, Alien,...more
6/20/2017
/ Arbitration ,
Blockchain ,
BSA/AML ,
Consent Order ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Card Surcharges ,
Credit Cards ,
Credit Reporting Agencies ,
Disclosure Requirements ,
Expressions Hair Design v Schneiderman ,
Fair Lending ,
FCC ,
FinTech ,
First Amendment ,
HERA ,
Lending ,
Money Laundering ,
Mortgages ,
OCC ,
Prepaid Payment Products ,
SCOTUS ,
Small Business ,
TCPA ,
Trump Administration