A Look at Recent Federal Trade Commission and Consumer Financial Protection Bureau Initiatives Concerning Privacy and Data Security
2BInformed: Engaging with EPA, OSHA’s New Regulation, and Asbestos
The CFPB intends to issue a proposed rule to address the impact of credit reporting relating to accounts of survivors of domestic violence, elder abuse, and other forms of financial abuse....more
On December 9, the Consumer Financial Protection Bureau (CFPB or Bureau) announced the launch of a rulemaking process addressing credit reporting on survivors of domestic violence, elder abuse, and other forms of financial...more
The Fifth Circuit Court of Appeals has set oral arguments for Oct. 7 in the challenge of the Federal Trade Commission’s Combating Auto Retail Scams Rule (“CARS Rule”). The petition, filed on January 5, 2024 by the National...more
In September 2023, the CFPB announced that it was launching a Fair Credit Reporting Act rulemaking and issued an outline of the proposals it is considering in preparation for convening a Small Business Advisory Review Panel. ...more
The Federal Deposit Insurance Corporation (“FDIC”) Board had a busy Tuesday. In addition to the release of an ANPR on Resolution Requirements for large banking organizations that we also write about this week, the FDIC Board...more
The Federal Reserve Board (“FRB”) and Federal Deposit Insurance Corporation (“FDIC”) Board issued an Advanced Notice of Proposed Rulemaking (“ANPR”) titled “Resolution-Related Resource Requirements for Large Banking...more
Financial institutions and fintech firms increasingly access consumer financial data and provide services to consumers using data from various financial accounts. This includes programs that assist consumers in managing...more
The Bureau of Consumer Financial Protection (CFPB or Bureau) has formally commenced its long-awaited rulemaking process to implement section 1033 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank...more
Final Post in a Three-Post Series Regarding Recent Regulatory Action by FinCEN - On September 29, 2020, the Financial Crimes Enforcement Network (“FinCEN”) published a request for comment on existing regulations regarding...more
The CFPB has announced that it plans to issue an advance notice of proposed rulemaking (ANPR) later this year on consumer-authorized access to financial records. The announcement was made concurrently with the Bureau’s...more
For the first time in a dozen years, the Office of the Comptroller of the Currency (OCC) is seeking to update its regulations on digital activities to consider banks’ use of blockchain and distributed ledger technology (DLT),...more
When the federal Consumer Financial Protection Bureau (“CFPB”) last summer issued its Advance Notice of Proposed Rule Making (“ANPR”) to revise the definition of a “Qualified Mortgage” (“QM”) under the Dodd-Frank Act’s...more
On Monday, September 9, 2019, a group of 28 housing, consumer protection and community development organizations issued a letter to the Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency and...more
The U.S. Department of Treasury recently issued the long-awaited Housing Reform Plan, and among various topics the Plan addresses the temporary qualified mortgage under the Regulation Z ability-to-repay rule for loans that...more
The Office of the Comptroller of the Currency (OCC) has issued an advance notice of proposed rulemaking (ANPR) on which it invites public comment “to solicit ideas for building a new framework to transform or on ways to...more
Lawmakers returned from their Independence Day recess prepared for more legislative fireworks over a slew of outstanding agenda items, including a showdown over the Supreme Court nomination of Judge Brett Kavanaugh to replace...more
Editor's Note - In This Issue.The SEC and FINRA released their examination priorities for 2017; the SEC’s Division of Investment Management issued an interpretative letter that would permit brokers to charge their own...more