Is it just us or does March 4 — the date of our last issue — feel like a million years ago? Like you, and not necessarily in this order, we have been: doing our work; keeping up with COVID-19-related laws, guidance, and...more
On June 3, 2020, the Consumer Financial Protection Bureau (CFPB) issued a statement announcing temporary supervisory and enforcement flexibility during the COVID-19 pandemic for credit card issuers regarding electronic...more
On June 3, 2020, the Consumer Financial Protection Bureau (CFPB) issued a Statement on Supervisory and Enforcement Practices Regarding Electronic Credit Card Disclosures in Light of the COVID-19 Pandemic (“Statement”) under...more
On May 13, 2020, the Consumer Financial Protection Bureau (CFPB) issued two sets of FAQs. The first set of FAQs is directed to providers of checking, savings, and prepaid accounts. The second set of FAQs is directed to...more
The CFPB has published its Fall 2019 rulemaking agenda as part of the Fall 2019 Unified Agenda of Federal Regulatory and Deregulatory Actions, which is coordinated by the Office of Management and Budget....more
On Tuesday evening, Sept. 17, ACA International filed a 155-page comment to the Consumer Financial Protection Bureau’s (“Bureau”) proposed debt collection rule. The comment advocates for consumers, creditors and a stable U.S....more
The CFPB (referring to itself as the Bureau of Consumer Financial Protection) has filed what appears to be its first amicus brief since former Director Cordray’s departure....more
The Structured Finance Spectrum is our newsletter featuring what’s new and newsworthy in structured finance—a look at what’s going on with the CFPB; significant developments in the regulatory, bankruptcy, and technology...more
What You Can Learn about Vendor Management from the DocuSign Breach While some industries may get away with the “trust but verify” model, heavily regulated industries such as financial services have no such luxury. Trust...more
On May 16, DocuSign confirmed that a data breach resulted in widespread malware phishing attacks targeting its customers. DocuSign provides electronic signature solutions for many companies in the mortgage banking industry...more
The final Prepaid Card Rule requires not only so-called “packaging” or short form disclosures prior to acquisition of the prepaid card account, but also that a long form disclosure be provided to the consumer. Whereas the...more
The Consumer Financial Protection Bureau (“CFPB”) issued a compliance bulletin (“Bulletin”) reminding entities of their obligation to obtain consumer authorization prior to automatically debiting a consumer’s account for...more
The CFPB has issued a compliance bulletin (Bulletin 2015-06) concerning the Electronic Fund Transfer Act (EFTA) and Regulation E requirements for obtaining a consumer’s authorization for preauthorized electronic fund...more