In This Issue:
- Beltway Report
- Bureau Report
- Mobile & Emerging Payments Report
- Mortgage & Fair Lending Report
- Operations Report
- Preemption Report
- Privacy Report
- Arbitration Report
- TCPA Report
- Excerpt from Beltway Report:
Unfair Yesterday, Today, and Tomorrow -
The Federal Reserve Board proposed to repeal Regulation AA, which contains the “credit practices rule” prohibiting banks from using certain provisions and remedies in consumer credit contracts. The proposed repeal is a matter of housecleaning to reflect changes required by the Dodd-Frank Act. Concurrently, the Board, the CFPB, the FDIC, the NCUA, and the OCC issued joint guidance clarifying that the repeal of the credit practices rules is not a determination that the prohibited practices contained in such rules are now permissible. The guidance explains that the conduct prohibited by Regulation AA may still be considered unfair or deceptive practices under the Federal Trade Commission (FTC) Act and the Dodd-Frank Act, even in the absence of specific regulation.
Please see full issue below for more information.