News & Analysis as of

Comment Period Financial Services Industry

Ballard Spahr LLP

CFPB proposes to rescind rule requiring nonbanks to register certain agency enforcement and court orders

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The CFPB is proposing to rescind its rule that requires certain nonbank entities to register covered agency enforcement and court orders....more

Orrick, Herrington & Sutcliffe LLP

CFPB proposes to rescind amendments to nonbank supervision

On May 14, the CFPB published a Federal Register notice withdrawing its proposed rule on the Procedures for Supervisory Designation Proceedings. These amendments were each codified in 12 C.F.R. 1091. As previously covered by...more

Troutman Pepper Locke

CFPB Proposes Rescission of Nonbank Registration Rule

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Yesterday, the Consumer Financial Protection Bureau (CFPB or Bureau) released a proposed rule to rescind its previous regulation requiring nonbank entities to report certain agency and court orders to a Bureau registry....more

Ballard Spahr LLP

CFPB extends comment period for data broker NPRM

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The CFPB has extended the comment period for its Notice of Proposed Rulemaking on data brokers until April 2, 2025; the comment period had been slated to expire on March 3, 2025....more

White & Case LLP

CFPB’s Proposed Rule Aims to Prohibit the Use of Certain Contractual Provisions in Consumer Financial Products or Services...

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Background, Purpose, and Structure of the Proposed Rule - On January 13, 2025, the Consumer Financial Protection Bureau (CFPB) published a proposed rule, which aims "to prohibit certain contractual provisions in agreements...more

Troutman Pepper Locke

NYC DCWP Further Delays Effective Date of Amended Debt Collection Rules

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In our previous post, we discussed the New York City Department of Consumer and Worker Protection’s (NYC DCWP) decision to delay the enforcement of the amended debt collection rules from December 1, 2024, to April 1, 2025....more

Orrick, Herrington & Sutcliffe LLP

CFPB issues new proposal to ban certain financial contract terms

On January 13, the CFPB proposed a new rule to ban large banks and consumer finance companies from using certain contractual provisions in agreements with consumers under Regulation AA. The CFPB’s proposal warns against the...more

Orrick, Herrington & Sutcliffe LLP

CFPB seeks comments on proposed interpretive rule expanding the application of the EFTA to a wide range of digital assets

On January 10, the CFPB proposed an interpretive rule that could significantly broaden the scope of the EFTA to encompass a broad range of digital assets, including—if they meet certain requirements — cryptocurrency accounts,...more

Ballard Spahr LLP

CFPB proposes rule to ban consumer contract terms bureau says limit ‘fundamental freedom’

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The CFPB has published a proposed rule that would ban companies from using contract clauses that the bureau said limit fundamental freedom, including those that waive a consumer’s legal rights and fine print that suppresses...more

A&O Shearman

UK Financial Conduct Authority consults on a new product information framework for consumer composite investments

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The U.K. Financial Conduct Authority has published a consultation on a new product information framework for Consumer Composite Investments. The regime will apply in respect of a CCI which is or may be distributed to a retail...more

A&O Shearman

European Securities and Markets Authority consults on the internal control framework for certain market agencies

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The European Securities and Markets Authority has published a consultation on draft guidelines on internal controls for benchmark administrators, credit rating agencies, and market transparency infrastructures (which include...more

A&O Shearman

European Securities and Markets Authority consults on the draft technical standards on open-ended loan-originating alternative...

A&O Shearman on

The European Securities and Markets Authority has published a consultation paper on draft regulatory technical standards on open-ended loan originating Alternative Investment Funds under the revised Alternative Investment...more

Orrick, Herrington & Sutcliffe LLP

CFPB seeks comment on ANPR to amend Regulation V

On December 9, the CFPB issued an advance notice of proposed rulemaking (ANPR) to request public comment on potential amendments to Regulation V, which implements the FCRA. As described by the CFPB, the ANPR would address...more

Troutman Pepper Locke

CFPB Initiates FCRA Rulemaking to Address Coerced Debt

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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

Orrick, Herrington & Sutcliffe LLP

Dept. of Veterans Affairs proposes to amend its guaranteed home loan program

Recently, the Department of Veterans Affairs (VA) proposed a rule to amend its regulations governing its VA-guaranteed home loan program to modernize and enhance reporting requirements and oversight. The proposed changes will...more

Hinshaw & Culbertson - Consumer Crossroads

New York City Department of Consumer and Worker Protection Proposes Amendments to its Definition of "Debt Collector"

In November 2024, the New York City Department of Consumer and Worker Protection (DCWP) proposed additional amendments to its rules relating to debt collectors to clarify the definition of a "debt collector."...more

A&O Shearman

Mansion House: UK Financial Conduct Authority and Financial Ombudsman Service Call for Input on Modernizing the Redress System

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The U.K. Financial Conduct Authority and the Financial Ombudsman Service have launched a joint call for input on modernizing the redress system. The two main concerns of the FCA and the FOS are mass redress events and FCA-FOS...more

A&O Shearman

UK Financial Conduct Authority Publishes Discussion Paper on Improving the UK Transaction Reporting Regime

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The U.K. Financial Conduct Authority has issued a discussion paper on potential options for improving the U.K. transaction reporting regime. The FCA has two primary objectives: to improve the usefulness of transaction...more

Troutman Pepper Locke

The CFPB Proposes New FCRA Rule to Dramatically Expand Its Scope, Though Finalization is Unlikely

Troutman Pepper Locke on

On December 3, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a proposed rule for public comment aimed at amending Regulation V, which implements the Fair Credit Reporting Act (FCRA). The proposed rule seeks...more

Ballard Spahr LLP

California’s DFPI seeks comments on additional products and services to be registered under the CCFPL

Ballard Spahr LLP on

In the wake of the Office of Administrative Law’s approval of its registration and reporting requirements for providers of income-based advances, private postsecondary education financing, debt settlement services, and...more

Nutter McClennen & Fish LLP

Nutter Bank Report: November 2024

The CFPB has adopted a final rule to extend its oversight to the largest nonbank providers of digital consumer payment applications, including those that enable transfers from deposit accounts held at banks and other insured...more

Troutman Pepper Locke

FDIC Extends Comment Period for Proposed Rule on Recordkeeping for Third-Party Deposits

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In a previous post, we discussed the Federal Deposit Insurance Corporation’s (FDIC) notice of proposed rulemaking aimed at enhancing recordkeeping for bank deposits received from fintech and other third-party, non-bank...more

A&O Shearman

Mansion House: UK Government Finalizes PISCES Policy

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In its consultation response, the government notes that the proposal to establish a PISCES Sandbox was well received as an appropriate way to develop and test this new regulatory regime. The government confirms that it will...more

A&O Shearman

Financial Action Taskforce Publishes Consultation on Changes to AML/CFT and Financial Inclusion Standards

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The Financial Action Taskforce has published a consultation paper on revisions to its anti-money laundering and counterterrorism financing standards relating to financial inclusion. The consultation is part of FATF's program...more

Orrick, Herrington & Sutcliffe LLP

GOP members of Financial Services Committee pen letter on bank-fintech partnerships

On October 30, Republican congressmembers serving on the U.S. House Committee on Financial Services responded to a joint Request for Information (RFI) issued by the OCC, the Fed and the FDIC. The RFI solicited input on...more

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