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Financial Institutions Non-Bank Lenders

Ballard Spahr LLP

Consumer Finance Monitor Podcast Episode: The CFPB’s Registry of Nonbanks and Circular that Certain Contract Terms Violate Law

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The CFPB recently issued yet another final rule the agency says will help deter violations of consumer protection laws. This rule requires certain nonbank entities to register with the CFPB upon becoming subject to any order...more

Hinshaw & Culbertson - Consumer Crossroads

CFPB Publishes Filing Instructions for its New Nonbank Registry for Repeat Offenders

On August 23, the Consumer Financial Protection Bureau (CFPB) issued its Filing Instructions Guide ("Guide") for Nonbank Registration pursuant to its Registry of Nonbank Covered Persons Subject to Certain Agency and Court...more

Husch Blackwell LLP

FDIC Publishes FAQs on the New FDIC Signage, Advertisement, and Deposit Insurance Misrepresentations Rule

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Last week, the Federal Deposit Insurance Corporation (FDIC) published Frequently Asked Questions on the final rule governing FDIC Official Signs and Advertising Requirements, False Advertising, Misrepresentation of Insured...more

K&L Gates LLP

Brussels Regulatory Brief: June 2024

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Antitrust and Competition - The European Commission to Take Action to Address Territorial Supply Constraints - On 24 May 2024, the EU Commissioner for Competition, Margrethe Vestager, announced that the European Commission...more

Mayer Brown

US Banking Regulators Finalize Nonbank Lending Reporting Requirements

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On May 22, 2024, the US federal banking regulators finalized a new set of reporting requirements for bank loans and commitments to fund finance facilities, private credit lenders, and other nonbank financial entities.This...more

Alston & Bird

CFPB Expands its Reach with Final Rule Establishing Nonbank Registry of Public Settlements, Consent Orders and Enforcement Actions

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What Happened? On June 3, 2024, the Consumer Financial Protection Bureau (CFPB or Bureau) issued its Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders Final Rule (the Final Rule), a 486-page rule...more

Alston & Bird

FSOC Issues Report on Nonbank Mortgage Servicing Highlighting Strengths, Vulnerabilities and Recommendations

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What Happened? In May 2024, the Financial Stability Oversight Council (FSOC or Council) issued a Report on Nonbank Mortgage Servicing (the Report). The Report recognizes the strengths of nonbank mortgage companies (NMCs) and...more

Brownstein Hyatt Farber Schreck

CFPB Publishes Final Nonbank Registry Rule

On June 3, the Consumer Financial Protection Bureau (CFPB) published a final rule to create a registry of nonbank companies that have entered into consent agreements or who have otherwise been found by the bureau to be in...more

Alston & Bird

Large Nonbank Ginnie Mae Issuers: Ginnie Mae Wants Your Recovery Plans

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What Happened? Following the release of the Financial Stability Oversight Council (FSOC) Report on Nonbank Mortgage Servicing, Ginnie Mae announced in APM 24-08 that certain large nonbank Ginnie Mae Issuers will now be...more

Cadwalader, Wickersham & Taft LLP

The European Commission Consults on Macroprudential Policies for ‘Shadow Banks’

Towards the end of 2023, non-bank financial intermediaries ("NBFIs") accounted for approximately 41% of the EU’s total financial assets, against a figure for banks of 36%. This dominance and growth, together with the...more

Ballard Spahr LLP

Treasury Issues Broad National Strategy for Combatting Illicit Financing

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Strategy Touts Regulations on Beneficial Ownership, Real Estate and Investment Advisers, but Bemoans Lack of Supervisory Resources for Non-Bank Financial Institutions...more

Alston & Bird

Iowa Adopts Mortgage Servicer Prudential Standards

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What Happened? Effective July 1, Iowa House File 2392 (the “Iowa Law”) enacts mortgage servicer prudential standards (codified in Chapter 535B of the Iowa Code) that largely follow those promoted by the Conference of State...more

Orrick, Herrington & Sutcliffe LLP

RegFi Episode 29: The CFPB’s Expanding Supervisory Authority of Fintechs and Other Non-Banks

In our latest look at the CFPB’s expanding supervisory authority of fintechs and other non-bank financial service providers, RegFi cohosts Jerry Buckley and Sasha Leonhardt welcome fellow Orrick partner — and former deputy...more

Ballard Spahr LLP

FDIC Chairman Gruenberg issues remarks at National Community Reinvestment Coalition on FDIC’s economic inclusion strategy

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FDIC’s Chairman Martin J. Gruenberg recently gave remarks at the National Community Reinvestment Coalition on the FDIC’s economic inclusion strategy.  ...more

Ballard Spahr LLP

House members urge CFPB to define “risk to consumers” in procedural rule on risk-based supervisory authority

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A bi-partisan group of House members has sent a letter to CFPB Director Chopra to express concern about the CFPB’s rule setting forth its procedures for establishing supervisory authority over nonbanks engaged in conduct that...more

Hudson Cook, LLP

CFPB Bites of the Month - 2023 Annual Review - Fintech

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In this article, we share a timeline of our monthly "bites" for 2023 applicable to fintech. The Consumer Financial Protection Bureau (CFPB) and its director, Rohit Chopra, continued the agency's focus on the everyday consumer...more

Epstein Becker & Green

The FTC Amends Safeguards Rule to Require Non-Banking Financial Institutions to Disclose Certain Security and Data Breaches

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On October 27, 2023, the Federal Trade Commission (“FTC”) approved an amendment to the Safeguards Rule that requires non-banking financial institutions (e.g., mortgage companies, mortgage brokers, and creditors) to notify the...more

WilmerHale

NYDFS Finalizes Amendments to Cybersecurity Regulations

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On November 1, 2023, New York Department of Financial Services (NYDFS or the “Department”) released the finalized revisions (the “Second Amendment”) to 23 NYCRR Part 500 (Part 500) – the most significant modifications to Part...more

Alston & Bird

FSOC Approves Analytic Framework for Financial Stability Risks and Guidance on Nonbank Financial Company Designations

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A&B Abstract: On November 3, 2023 the Financial Stability Oversight Council (hereinafter “FSOC” or “Council”) unanimously approved final versions of: (1) the new Analytic Framework for Financial Stability Risk...more

Alston & Bird

FTC Approves New Data Breach Notification Requirement for Nonbanking Financial Institutions

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With an amendment to its Safeguards Rule, the Federal Trade Commission has joined other federal agencies regulating cybersecurity breaches. Our Privacy, Cyber & Data Strategy Team analyzes how the amendment will affect...more

Constangy, Brooks, Smith & Prophete, LLP

FTC Non-Banking Financial Institutions Safeguards Rule

The Federal Trade Commission has approved an amendment to the Safeguards Rule under the Gramm-Leach-Bliley Act that creates a new data privacy regulatory reporting requirement for non-banking financial entities. Covered...more

Polsinelli

FTC Adopts Data Breach Notification Obligations for Non-Banking Financial Institutions

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On October 27, 2023, the Federal Trade Commission (“FTC”) adopted an amendment to the FTC’s Safeguards Rule that will require non-banking financial institutions to notify the FTC within thirty days of discovering a data...more

Jones Day

FTC Requires Non-Bank Financial Institutions to Report Data Security Breaches Under Amended Safeguards Rule

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On Friday, October 27, the Federal Trade Commission ("FTC") announced new amendments to the Safeguards Rule, requiring covered financial institutions to report certain data breaches to the FTC and reflecting its continuing...more

Spilman Thomas & Battle, PLLC

Promissory Notes - Banking & Finance Insights: V 3, Issue 8, November 2023

FTC Amends Safeguards Rule to Require Non-Banking Financial Institutions to Report Data Security Breaches - “Amendment will require non-bank financial institutions to report when they discover that information affecting...more

Sheppard Mullin Richter & Hampton LLP

FTC Amends Safeguards Rule, Requires Non-Banks to Report Data Security Breaches

On October 27, the FTC has approved an amendment to the Safeguards Rule that would require non-banking institutions to report certain data breaches and other security events to the agency. The amendment requires financial...more

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