MoFo Reenforcement

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Firm Profile: Morrison & Foerster LLP
425 Market Street
San Francisco, CA 94105-2482, United States
Phone: (415) 268-7000
Fax: (415) 268-7522
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Take Two: State AGs Target The FDIC’s Final Rule Reaffirming Valid-When-Made Doctrine

Last week, the state attorneys general of seven states and the District of Columbia filed suit against the Federal Deposit Insurance Corporation (FDIC) challenging the FDIC’s final rule reaffirming the valid-when-made doctrine…more
 /  Administrative Law, Finance & Banking

Financial Services Report – Spring 2019

EDITOR’S NOTE - In the words of Willie Wonka: “Wait a minute — strike that, reverse it!” As loyal readers will recall, in our last issue, we tried to stay current in referring to the CFPB by what Mick Mulvaney declared would…more
 /  Alternative Dispute Resolution (ADR), Finance & Banking, Privacy, Consumer Protection

CFPB Initiates Fourth Review of the Consumer Credit Card Market

On January 31, 2019, the Consumer Financial Protection Bureau (CFPB or Bureau) published a Request for Information (2019 RFI) regarding the consumer credit card market. In accordance with Section 502(a) of the Credit Card…more
 /  Consumer Protection, Finance & Banking

CFPB and New York Attorney General Announce Settlement with Retailer for Violations of TILA and CFPA

On January 16, 2019, the Consumer Financial Protection Bureau (CFPB) and the New York Attorney General announced a settlement with a retailer for alleged violations of the Consumer Financial Protection Act of 2010 (CFPA) and the…more
 /  Consumer Protection, Finance & Banking

CFPB Announces Settlement for Violations of the EFTA and CFPA

On January 3, 2019, the Consumer Financial Protection Bureau (CFPB) announced a settlement with a federal savings bank for alleged violations of the Electronic Fund Transfer Act (EFTA) and Regulation E, as well as alleged…more
 /  Consumer Protection, Finance & Banking

The Bureau of Consumer Financial Protection Proposes Revised No-Action Letter Policy and New Product Sandbox

On December 13, 2018, the Bureau of Consumer Financial Protection (the “Bureau”) published in the Federal Register a proposed policy (“Proposed Policy”), which would modify its 2016 Policy on No-Action Letters (the “2016…more
 /  Consumer Protection, Finance & Banking

California Enacts a First-of-Its-Kind Commercial Financing Disclosure Law

On September 30, 2018, California Governor Jerry Brown signed into law SB 1235 (the Act), which requires disclosures of key terms in connection with certain commercial financing by non-banks and could impact bank/non-bank…more
 /  Business Organizations, Finance & Banking

Federal Agencies Reaffirm that Supervisory Guidance Is Not Law – Who Knew?

Yesterday, September 11, 2018, five federal agencies – the Federal Reserve Board, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency, and the Bureau…more
 /  Consumer Protection, Finance & Banking

The CFPB Catches Up to the FAST Act: Implements GLBA Annual Notice Exception

On August 17, 2018, the Bureau of Consumer Financial Protection (CFPB) published a final rule amending its Regulation P to include an exception to the Gramm-Leach-Bliley Act (GLBA) annual privacy notice obligation. Nearly three…more
 /  Consumer Protection, Finance & Banking

Senate Passes Financial Regulatory Reform Bill

On March 14, 2018, the U.S. Senate passed S. 2155, the “Economic Growth, Regulatory Relief, and Consumer Protection Act.” If enacted into law, S. 2155 would provide modest regulatory relief to regional and community banks, among…more
 /  Finance & Banking

Financial Services Report – Spring 2018

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 in…more
 /  Alternative Dispute Resolution (ADR), Consumer Protection, Finance & Banking, Privacy, Science, Computers, & Technology

Financial Services Report – Winter 2017

EDITOR’S NOTE - The holidays came early for the financial services industry. First, the Senate voted to repeal the CFPB’s rule banning class waivers in arbitration agreements in consumer financial contracts. Then, Richard…more
 /  Administrative Law, Business Organizations, Communications & Media Law, Consumer Protection, Finance & Banking

CFPB Encourages Financial Institutions to Provide Consumers with Greater Control over Payment Methods

Following the Equifax security breach, it was reported that the Consumer Financial Protection Bureau (CFPB) started to focus on cardholder transaction controls, such as how they are being offered in the marketplace to aid in…more
 /  Consumer Protection, Finance & Banking

Financing Fintech: ILC Charters

An ILC, or industrial loan company, is a form of bank that can be chartered in Utah, Nevada, and a few other states. ILCs are insured by the FDIC and have most traditional banking powers, but they cannot hold corporate checking…more
 /  Business Organizations, Finance & Banking, Science, Computers, & Technology

CFPB Makes HMDA Data Sharing Proposal

The CFPB announced on Wednesday, September 20th, 2017, proposed guidance to limit the Home Mortgage Disclosure Act (HMDA) data it shares publicly. The Bureau’s 2015 HMDA amendments revamped HMDA’s coverage and processes,…more
 /  Consumer Protection, Finance & Banking, Real Estate - Residential, Science, Computers, & Technology
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