Regulatory Developments - CFPB Issues Interpretive Rule: Tech Firms and Digital Marketers Acting as Service Providers Are Subject to CFPA - On August 10, the CFPB issued an interpretive rule clarifying that tech firms...more
All firms should take note of the FCA’s latest feedback on SMCR implementation. In its latest piece of feedback on firms’ implementation of the SMCR, the FCA indicated that firms must improve their implementation of the...more
A former CFPB examiner has written U.S. Attorney General Jeff Sessions claiming that CFPB officials falsified examination reports in connection with a CFPB examination of ACE Cash Express that led to the CFPB extracting $10...more
Since Mick Mulvaney’s appointment by President Trump as CFPB Acting Director, there have been widespread media reports about Mr. Mulvaney’s plans to impose a freeze on the CFPB’s collection of personally identifiable...more
In conjunction with its public event yesterday on student loan servicing, the CFPB issued a new report, “Staying on track while giving back.” The report, which provides a mid-year update on student loan complaints,...more
Georgia revised provisions under the Residential Mortgage Act, including, but not limited to, the following: An applicant for a mortgage lender license must provide a bond of $250,000, previously $150,000. This will...more
At the program held on April 7 entitled “The State of Consumer Protection Initiatives” at the American Bar Association Business Law Section Consumer Financial Services Committee 2017 Spring Meeting, Peggy Twohig, the CFPB’s...more
In its Fall 2016 Supervisory Highlights, which covers supervision work generally completed between May and August 2016, the CFPB highlights violations found by its examiners involving origination and servicing of auto...more
On Monday the CFPB released updated examination procedures for student loans. This update revises and expands on a previous update that was released in December 2013 in conjunction with the CFPB’s “larger participants” rule...more
On October 17, the FDIC released revised interagency Military Lending Act (MLA) examination procedures for use in connection with consumer credit transactions occurring on or after October 3, 2016. The revised procedures...more
The Department of Defense (DoD) has issued an interpretive rule to assist the industry in complying with its July 2015 final rule amending the Military Lending Act’s implementing regulation. The much-anticipated guidance was...more
In an unmistakable warning shot to mortgage servicers, the CFPB recently issued a “Mortgage Servicing Special Edition” of its Supervisory Highlights. The CFPB also updated portions of its Mortgage Servicing Examination...more
Below is a summary of recent investment management developments that affect registered investment companies, private equity funds, hedge funds, investment advisers, and others in the investment management industry. ...more
The CFPB sent industry trade groups a letter on October 1, 2015 to address the approach of the Federal Financial Institutions Examination Council (FFIEC) member agencies during the initial months following the implementation...more
The CFPB sent industry trade groups a letter on October 1, 2015 to address the approach of the FFIEC member agencies during the initial months following the implementation of the TILA-RESPA Integrated Disclosure (TRID) rule...more
The Office of the Comptroller of the Currency (OCC) recently released an updated and substantially revised section of its Comptroller’s Handbook titled “Retail Nondeposit Investment Products” (the Booklet). The Booklet...more
Prudential bank regulators and other supervisory authorities have put cybersecurity front and center in 2015 by issuing guidance that sets forth their expectations of improved cybersecurity and that incorporates cybersecurity...more
Why it matters - The OCC’s most recent report on current key risks should be read by all banks, regardless of size or regulator, as a road map in preparing for the next examination. Few banks would ever admit they may...more