News & Analysis as of

No-Action Letters Banking Sector

Ballard Spahr LLP

CFPB scraps no action letter and compliance assistance sandbox programs and creates new Office of Competition and Innovation

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The CFPB announced earlier this week that as part of a new approach to innovation in consumer finance, it is replacing its Office of Innovation and Operation Catalyst with a new office, the Office of Competition and...more

Orrick, Herrington & Sutcliffe LLP

FinCEN Pursues Its Next Steps, Posting its Priorities and Pondering a No-Action Process

The Financial Crimes Enforcement Network (FinCEN) has completed two of its early benchmark obligations arising out of the recently passed Anti-Money Laundering Act of 2020 (the “AML Act”)... First, pursuant to the AML Act,...more

Goodwin

House Votes to Repeal OCC True Lender Rule

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In This Issue. The House of Representatives voted to pass a Congressional Review Act resolution repealing the Office of the Comptroller of the Currency’s (OCC) “true lender” rule; the Consumer Financial Protection Bureau...more

WilmerHale

FinCEN Publishes No-Action Letter Analysis and AML/CFT National Priorities

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The Financial Crimes Enforcement Network (“FinCEN”) has continued a spate of regulatory activity related to financial crimes compliance matters in the first year of the Biden Administration, recapped in its recent report...more

Goodwin

CFPB To Revisit Trump-Era QM Final Rules

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In this Issue. The Consumer Financial Protection Bureau (CFPB) issued a statement announcing its intention to revisit Trump-era qualified mortgage (QM) final rules; the Biden Administration announced changes to the Small...more

Perkins Coie

Fintech Week in Review - December 2020 #2

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House Financial Services Committee Sets Fintech Priorities for a New Administration - House Financial Services Committee Chairwoman Maxine Waters sent a letter to the incoming administration with nearly 50 pages of...more

Goodwin

ISS Publishes 2021 Proxy Voting Guidelines

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In the News. Institutional Shareholder Services (ISS) published its proxy voting guidelines updates for 2021, which include new and updated voting recommendations on federal forum and exclusive forum provisions in companies’...more

Goodwin

CFPB Grants No-Action Letter for Proposed Small-Dollar Credit Product

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In the News. The Consumer Financial Protection Bureau (CFPB) granted a no-action letter (NAL) regarding a proposed small-dollar credit product and sought comment on the CFPB’s plan to study how consumers locate, comprehend...more

Ballard Spahr LLP

CFPB issues no-action letter to bank for small-dollar loan product

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The CFPB has issued a no-action letter (NAL) to a bank to facilitate the bank’s ability to offer a small-dollar loan product....more

Goodwin

Financial Services Weekly News: Regulators Propose Easing Volcker Rule Restrictions

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In This Issue. Federal financial regulators brought January to an impactful conclusion last week. On the morning of January 30, five federal financial regulators issued a proposed rule that would fundamentally modify the...more

Kilpatrick

State Attorneys General Criticize the CFPB’s Proposal to Create a Fintech Regulatory Sandbox and Revise its No-Action Letter...

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We have previously reported on the initiatives of the Consumer Financial Protection Bureau (CFPB or Bureau) to foster innovation in the fintech sector. In December 2018, the CFPB issued proposed revisions to its 2016 final...more

Nutter McClennen & Fish LLP

Fintech in Brief: Issues to Consider in Connection with the CFPB’s Proposed Product Sandbox and Policy Changes for No-Action...

Bank, nonbank, and Fintech providers of consumer financial products and services may be able to reduce their exposure to compliance risk under the December 13, 2018 No Action Letter (“NAL”) Policy changes proposed by the...more

Goodwin

Financial Services Weekly News - March 2018 #3

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Editor's Note - D.C. Circuit Strikes Down Key Pieces of FCC’s TCPA Interpretive Order. On March 16, the U.S. Court of Appeals for the D.C. Circuit issued its long-awaited decision in ACA International v. FCC, invalidating...more

Ballard Spahr LLP

CFPB Provides Some Clarity on Alternative-Data Models Through No-Action Letter

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On September 14, 2017, the CFPB issued a no-action letter – the first one ever issued by the agency – to a marketplace lender, stating that the agency had no present intention to take enforcement or supervisory action against...more

Robins Kaplan LLP

Your Daily Dose of Financial News

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The CFPB issued a no-action letter to Upstart Network this week that will allow the online lender to “continue using alternative credit data to evaluate borrowers in exchange for providing data to the federal consumer finance...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

FHFA Updates Progress on Fannie Mae and Freddie Mac Credit Risk Transfer Programs - On July 26, 2017, the Federal Housing Finance Agency released an update on the credit risk transfer programs of Freddie Mac and Fannie Mae...more

Ballard Spahr LLP

Director Cordray and Comptroller Curry speak at LendIt USA conference

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Earlier this week, we attended the LendIt USA conference in New York City, a leading annual fintech conference, at which CFPB Director Richard Cordray and Comptroller of the Currency Thomas Curry both spoke....more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

FHFA Issues Final Rule on Fannie Mae and Freddie Mac Duty to Serve Underserved Markets - On December 13, 2016, the Federal Housing Finance Agency (FHFA) issued a final rule implementing the Duty to Serve provisions...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

Financial Industry Developments - Agencies Publish Study on Banking Activities and Investments under Dodd-Frank - On September 8, 2016, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance...more

Ballard Spahr LLP

Director Cordray defends CFPB positions in appearance before Senate Banking Committee; comments on small business lending and...

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Much of Director Cordray’s testimony in his appearance before the Senate Banking Committee yesterday consisted of his predictable defense of various CFPB positions. While the hearing was much less contentious than last...more

Ballard Spahr LLP

Banking trade groups comment on CFPB’s proposed no-action letter policy

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The American Bankers Association, American Bankers Insurance Association and Consumers Banking Association have submitted a joint comment letter on the CFPB’s proposed policy on issuing “no-action” letters for innovative...more

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