As we reported in our Client and Friends memo last month, the Third Circuit published an opinion on March 19th finding that statutory trusts such as those that make up the National Collegiate Student Loan Trusts (the “NCSLT...more
On March 19, 2024, the Third Circuit handed down a decision that statutory trusts used as issuing entities for securitizations are considered “covered persons” for purposes of the Consumer Financial Protection Act ("CFPA"),...more
In February 2022, the Securities and Exchange Commission (the “SEC” or the “Commission”) proposed sweeping new regulatory requirements under the Investment Advisers Act of 1940, as amended (the “Advisers Act”) for investment...more
On December 16, 2022, the Board of Governors of the Federal Reserve System (the “Board”) adopted a final rule (the “Final Rule”) to implement the Adjustable Interest Rate (LIBOR) Act (the “LIBOR Act”). The Final Rule follows...more
On July 11, 2022, the Alternative Reference Rates Committee (the “ARRC”) published a “Playbook” to assist market participants in transitioning their legacy LIBOR contracts to an alternative rate by June 30, 2023. The...more
On April 29, 2022, the U.S. Court of Appeals for the Third Circuit granted a petition for permission to appeal in Consumer Financial Protection Bureau v. The National Collegiate Master Student Loan Trusts filed by defendants...more
5/5/2022
/ Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Enforcement Actions ,
Enforcement Authority ,
Financial Services Industry ,
Interlocutory Appeals ,
Securitization Vehicles ,
Statute of Limitations ,
Statutory Interpretation ,
Statutory Violations ,
Student Loans ,
Unfair or Deceptive Trade Practices
On February 11, 2022, the U.S. District Court for the District of Delaware granted a motion for interlocutory appeal in Consumer Financial Protection Bureau v. The National Collegiate Master Student Loan Trusts filed by...more
2/16/2022
/ Appellate Review ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Covered Person ,
Debt Collection ,
Enforcement Actions ,
Enforcement Authority ,
Financial Services Industry ,
Interlocutory Appeals ,
Statutory Interpretation ,
Statutory Violations ,
Student Loans ,
Unfair or Deceptive Trade Practices
On December 13, 2021, Judge Stephanos Bibas, visiting judge in the U.S. District Court for the District Delaware from the U.S. Court of Appeals for the Third Circuit, denied a motion to dismiss a lawsuit brought by the...more
12/16/2021
/ Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Covered Person ,
Debt Collection ,
Financial Services Industry ,
Lenders ,
Motion to Dismiss ,
Securitization ,
Statutory Trusts ,
Statutory Violations ,
Student Loans ,
Third-Party Service Provider
California’s ambitious new data privacy law, the California Consumer Privacy Act of 2018 (“CCPA”), will go into effect on January 1, 2020 and promises to bring a new era of digital regulation to America’s shores. ...more
3/4/2019
/ California Consumer Privacy Act (CCPA) ,
Consumer Privacy Rights ,
Cybersecurity ,
Data Collection ,
Data Privacy ,
Data Protection ,
Financial Institutions ,
Financial Services Industry ,
General Data Protection Regulation (GDPR) ,
Personal Data ,
Personally Identifiable Information ,
Privacy Laws