News & Analysis as of

Constitutional Challenges Banking Sector

Troutman Pepper Locke

Fifth Circuit Agrees to Dismiss CFPB’s UDAAP Examination Manual Appeal, Aligning with Bureau’s New Regulatory Priorities

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On May 1, the U.S. Court of Appeals for the Fifth Circuit dismissed the Consumer Financial Protection Bureau’s (CFPB or Bureau) appeal concerning the vacated amendments to its Unfair, Deceptive, or Abusive Acts and Practices...more

Orrick, Herrington & Sutcliffe LLP

NCUA board members challenge unprecedented removal by President Trump

On April 28, a complaint was filed in the U.S. District Court for the District of Columbia, challenging the removal of two Senate-confirmed members of the NCUA Board by President Trump. The plaintiffs allege that their...more

Orrick, Herrington & Sutcliffe LLP

Bank responds to CFPB’s amended complaint and alleges improper delay tactics

On March 17, a bank again asked the U.S. District Court for the Northern District of Texas to dismiss the CFPB’s suit against the bank. As previously covered by InfoBytes, the Bureau filed an amended complaint after the...more

Snell & Wilmer

FDIC Reverses Position on the Constitutionality of In-House Administrative Law Judges

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After several Supreme Court decisions and Executive Orders upended many of the norms governing the relationship between governmental agencies and the constitutional branches, a recent decision by the Federal Deposit Insurance...more

Orrick, Herrington & Sutcliffe LLP

District court grants partial preliminary injunction in case challenging Illinois law on interchange fees

Recently, the U.S. District Court for the Northern District of Illinois Court granted a partial preliminary injunction sought by banking associations against the Illinois Attorney General over the Illinois Interchange Fee...more

Bradley Arant Boult Cummings LLP

Kansas Bank's Suit Could Upend FDIC Enforcement Authority

On Nov. 19, 2024, the Federal Deposit Insurance Corp. issued a notice of assessment finding that between December 2018 and August 2020, CBW Bank — a single-branch bank in Weir, Kansas — failed to maintain an adequate...more

Blank Rome LLP

Illinois Loses First Shot at Interchange Fees on State and Local Taxes

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Illinois enacted a law that prohibits a credit card holder’s bank from charging or receiving interchange fees on the portions of transactions that include Illinois state or local taxes and gratuities, in effect starting July...more

Blake, Cassels & Graydon LLP

Autorité des marchés financiers c. Ordre des comptables professionnels agréés du Québec : Les limites du secret professionnel des...

Le 12 novembre 2024, la Cour d’appel du Québec a rendu une décision importante dans l’affaire Autorité des marchés financiers c. Ordre des comptables professionnels agréés du Québec. Cet arrêt concerne l’article 17.0.1 de la...more

Orrick, Herrington & Sutcliffe LLP

State chartered bank challenges constitutionality of FDIC enforcement proceedings

On November 19, a Kansas state chartered bank filed a complaint for declaratory and injunctive relief against the FDIC and two Administrative Law Judges (ALJs) from the Office of Financial Institution Adjudication. The...more

Orrick, Herrington & Sutcliffe LLP

DDC tosses case challenging constitutionality of FDIC imposing civil penalties

On October 11, the U.S. District Court for the District of Columbia (DDC) denied an individual plaintiff’s motion for a temporary restraining order (TRO) and granted the FDIC’s motion to dismiss in a case seeking to enjoin an...more

Orrick, Herrington & Sutcliffe LLP

Suit against FDIC argues the agency is “unconstitutional” and violates Jarkesy

Recently, the U.S. District Court for the District of Columbia received a complaint from an individual plaintiff suing the FDIC, its heads, board members and an administrative law judge (ALJ) for allegedly subjecting the...more

Allen Matkins

Bank Runs And Social Media

Allen Matkins on

In this post from 14 years ago, I speculated as to whether California Financial Code Section 1327 was constitutional.  Two years later, the California Court of Appeal declared the statute unconstitutional.   Summit Bank v....more

Seward & Kissel LLP

[Webinar] FinTech Forum: Emerging Trends in the Legal and Regulatory Landscape - May 18th, 1:30 pm - 5:30 pm ET

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Seward & Kissel and The Berkeley Center for Law and Business invite you to the inaugural FinTech Forum, which will be held Thursday, May 18, 2023. The event will highlight emerging trends in the legal and regulatory...more

Troutman Pepper Locke

Initial Reactions to the Fifth Circuit CFSA Decision - The Consumer Finance Podcast

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Please join Consumer Financial Services Partner Chris Willis and his colleague Partner Misha Tseytlin to discuss the Fifth Circuit's decision in Community Financial Services Association of America, Ltd. v. Consumer Financial...more

Foster Garvey PC

The Washington State Supreme Court Renders a Decision Impacting Financial Institutions Doing Business in the State

Foster Garvey PC on

On September 30, 2021, the Washington State Supreme Court upheld the constitutionality of the additional 1.2 percent business and occupation (B&O) tax imposed by the 2019 Substitute House Bill 2167 (“SHB 2167”) on “specified...more

Genova Burns LLC

The IEs are Coming: Regulated-Industry Companies Now Free to Make Independent Expenditures in NJ

Genova Burns LLC on

Late yesterday, the United States District Court of the District of New Jersey held that a century-old statute “does not ban any entity from making independent expenditures” in New Jersey. The decision comes just in time for...more

Goodwin

SEC Adopts Rule Providing New Regulatory Framework For Fund-Of-Funds

Goodwin on

In the News. The Securities and Exchange Commission (SEC) announced that it adopted Rule 12d1-4 under the Investment Company Act of 1940 (the 1940 Act), providing a new regulatory framework for fund-of-funds and final...more

Goodwin

Financial Services Weekly Roundup: The Supreme Court Strikes Back On Single Director Leadership Structures

Goodwin on

In This Issue. The U.S. Supreme Court struck down the single director leadership structure of the Consumer Financial Protection Bureau (CFPB) in a ruling that could have far-reaching implications for the CFPB and other...more

McGuireWoods LLP

If the CFPB is Unconstitutional, Can Its Prior Actions be Unwound?

McGuireWoods LLP on

There are widespread expectations that the Supreme Court, following an oral argument last week, may rule that part of the law that created the CFPB is unconstitutional. As a result, many business executives, in particular,...more

Ballard Spahr LLP

Four Amicus Briefs Filed in All American Check Cashing Case Addressing Constitutionality of CFPB Structure

Ballard Spahr LLP on

On September 17, 2018, four Amici filed briefs in the CFPB’s case against All American Check Cashing, which is now before the Fifth Circuit Court of Appeals. The Court is considering whether the structure of the CFPB is...more

Ballard Spahr LLP

Petition for certiorari filed by State National Bank of Big Spring raising constitutional challenge to CFPB

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A petition for certiorari was filed in the U.S. Supreme Court late last week by State National Bank of Big Spring (SNB) which, together with two D.C. area non-profit organizations that also joined in the petition, had brought...more

Robins Kaplan LLP

Your Daily Dose of Financial News

Robins Kaplan LLP on

The SEC has taken its first enforcement action against a hedge fund over its cryptocurrency investments—namely, falsely holding itself out as the “first regulated fund in the U.S. focused on crypto assets.” It also targeted a...more

Nutter McClennen & Fish LLP

Nutter Bank Report, July 2018

Headlines - ...Guidance Issued on Immediate Implementation of Certain Provisions of the EGRRCPA ...Federal Appeals Court Rules That the FHFA Is Unconstitutionally Structured ...OCC Issues Updated Guidance on...more

Perkins Coie

Court Rules That Consumer Financial Protection Bureau Is Unconstitutional

Perkins Coie on

Summary of SDNY order holding that CFPB is unconstitutional - CFPB v. RD Legal Funding, LLC, 17-cv-890 (June 21, 2018, S.D.N.Y.) - Last week, a federal court in New York ruled that the entire Consumer Financial...more

Ballard Spahr LLP

Senate Banking Committee Probes Mulvaney’s Leadership at the CFPB

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On April 12, 2018, Mick Mulvaney, the Acting Director of the Consumer Financial Protection Bureau (Bureau) testified before the Senate Committee on Banking, Housing, and Urban Affairs regarding the Bureau’s Semi-Annual Report...more

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