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No-Action Letters Consumer Financial Products

Troutman Pepper Locke

The CFPB Issues Revised Sandbox and No-Action Letter Policies

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Earlier this month, the Consumer Financial Protection Bureau (CFPB or Bureau) issued new policy statements regarding its Compliance Assistance Sandbox (CAS) and No-Action Letters (NAL) programs. ...more

Mayer Brown

New Action on No-Action Letters – CFPB Begins Accepting Applications Under Updated No-Action Letter Procedures

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The US Consumer Financial Protection Bureau (CFPB) is giving no-action letters (NALs) a second chance. On January 8, 2025, the CFPB issued a policy statement setting forth new procedures for companies to request supervisory...more

Clark Hill PLC

CFPB Reboots No-Action Letter and Sandbox Policies: A New Approach to Financial Innovation…Not

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On January 3, 2025, the Consumer Financial Protection Bureau (CFPB) announced a comprehensive reboot of its No-Action Letter (NAL) and Compliance Assistance Sandbox (CAS) policies. The proposed policies on its face, marks a...more

Husch Blackwell LLP

CFPB Reboots Policy Statements for No-Action Letters and Compliance Assistance Sandbox Approvals Days Before Administration Change

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On January 10, 2025, the Consumer Financial Protection Bureau (CFPB) revived its policy statements on No-Action Letters (NALs) and Compliance Assistance Sandbox (CAS) Approvals. These unexpected changes come just days before...more

Ballard Spahr LLP

CFPB re-establishes regulatory sandbox, no-action letter programs

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In an effort to foster innovation in financial services, the CFPB is reinstituting its programs that allow companies to obtain regulatory safe harbors through no-action letters and sandboxes to test new products and services....more

Ballard Spahr LLP

House Financial Committee to hold Dec. 5 hearing on financial innovation

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Today, the House Financial Services Committee’s Subcommittee on Digital Assets, Financial Technology and Inclusion will hold a hearing entitled “Fostering Financial Innovation: How Agencies Can Leverage Technology to Shape...more

Carlton Fields

Expect Focus - Volume III, September 2023

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Regulators Hit Jackpot: Off-Channel Communications - Several years before announcing the first “off-channel” communications enforcement action, the SEC and FINRA cautioned broker-dealers and investment advisers about...more

Wiley Rein LLP

Wiley Consumer Protection Download (June 21, 2022)

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Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more

Ballard Spahr LLP

CFPB issues order terminating Upstart no-action letter

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The CFPB issued an order last week terminating the no-action letter issued to Upstart Network, Inc. on November 30, 2020 for a 36-month term (NAL).  The NAL was essentially a renewal of the no-action letter issued to Upstart...more

Sheppard Mullin Richter & Hampton LLP

CFPB Announces Opening of New Office of Competition and Innovation

On May 24, CFPB announced the opening of the Office of Competition and Innovation, as part of its new approach to increase competition amongst consumer financial service companies by identifying barriers to entry for new...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

Goodwin

CFPB Issues No Action Letter Related to Use of Artificial Intelligence Underwriting Model

Goodwin on

On November 30, 2020, the Consumer Financial Protection Bureau (CFPB) granted a no-action letter​ to an online loan marketplace company for its artificial intelligence (AI) loan origination and underwriting platform.​ ...more

Hudson Cook, LLP

CFPB Bites of the Month - November Top 10

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Each month, we host a 30-minute webinar outlining the month's key announcements and takeaways from the CFPB to be considered by financial services providers. In this month's article, we share our top "bites" covered during...more

Goodwin

ISS Publishes 2021 Proxy Voting Guidelines

Goodwin on

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

Wiley Rein LLP

Wiley Consumer Protection Download (November 9, 2020)

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Regulatory Announcements - CFPB Issues No Action Letter to Facilitate Consumer Access to Loans. The Consumer Financial Protection Bureau (CFPB) issued a No-Action Letter to Bank of America, N.A. on November 5 regarding...more

Skadden, Arps, Slate, Meagher & Flom LLP

Consumer Financial Protection Bureau Launches Advisory Opinion Process

On June 18, 2020, the Consumer Financial Protection Bureau (CFPB or Bureau) announced the pilot of a new Advisory Opinion process, offering a potentially useful tool for those seeking guidance on compliance issues. ...more

Ballard Spahr LLP

CFPB Issues No-Action Letter Template For Small-Dollar Loan Products Offered By Depository Institutions And Credit Unions

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In the aftermath of a statement from the CFPB and the four federal banking agencies encouraging small-dollar lending in response to the COVID-19 pandemic and guidance from the four federal banking agencies on “Interagency...more

Skadden, Arps, Slate, Meagher & Flom LLP

Summary of 28th Annual Conference on Fair Lending and Consumer Financial Protection

Year In Review - Anand Raman, the head of Skadden’s Consumer Financial Services (CFS) practice, began the conference by providing a summary of notable events and trends over the past year relating to consumer financial...more

Ballard Spahr LLP

Paul Watkins, Director of the CFPB’s Office of Innovation, discusses final innovation policies in Ballard Spahr webinar

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Paul Watkins, Director of the CFPB’s Office of Innovation, joined Ballard Spahr partners Alan Kaplinsky and James Kim yesterday for a discussion of the CFPB’s final innovation policies.  ...more

Bradley Arant Boult Cummings LLP

The CFPB (Yes, the CFPB!) Offers New Compliance Tools for Innovation

Companies that offer innovative consumer financial products and services have new tools to help them stay in compliance with federal consumer financial laws. In a refreshing twist from prior policy, the Consumer Financial...more

Ballard Spahr LLP

CFPB addresses RESPA issue in its first no-action letter under the revised final policy

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In its first No-Action Letter under the new revised policy, the CFPB addresses a long-standing issue under the Real Estate Settlement Procedures Act regarding certain payment arrangements between mortgage lenders and housing...more

Ballard Spahr LLP

CFPB finalizes product sandbox proposal and changes to trial disclosure, no-action letter policies; discloses plans to propose...

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The CFPB has finalized its proposed revisions to its Policy to Encourage Trial Disclosure Programs” (TDP Policy) and policy on “no-action” letters (NAL Policy) and has also finalized its proposal to create a new “product...more

Ballard Spahr LLP

CFPB gives boost to use of alternative data and machine learning

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A new CFPB blog post titled “An update on credit access and the Bureau’s first No-Action Letter” provides a boost to lenders using alternative data and machine learning in their underwriting models....more

Ballard Spahr LLP

CFPB clarifies coverage of “disclosure sandbox” proposal; consumer groups comment on proposed revisions to no-action letter policy...

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“Disclosure Sandbox.”  In September 2018, the Bureau proposed significant revisions to its “Policy to Encourage Trial Disclosure Programs” which sets forth the Bureau’s standards and procedures for exempting individual...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

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