Consumer Finance Monitor Podcast Episode: The CFPB’s Registry of Nonbanks and Circular that Certain Contract Terms Violate Law
The Future of Digital Consumer Payment Applications: CFPB's Proposed Larger Participant Rule – The Consumer Finance Podcast and Payments Pros Podcast
Podcast: Private Fund Regulatory Update: Post-U.S. Government Shutdown
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
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
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
FDIC’s Chairman Martin J. Gruenberg recently gave remarks at the National Community Reinvestment Coalition on the FDIC’s economic inclusion strategy. ...more
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
On January 9, a group of five bi-partisan South Carolina Senators introduced Bill 910, which would, among other things, require persons (non-bank lenders) providing “consumer installment loans” or “deferred presentment loans”...more
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
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
On October 27, 2023, the Federal Trade Commission (FTC) issued a final rule (Final Rule) to amend the Standards for Safeguarding Customer Information (Safeguards Rule). This amendment will require non-bank financial...more
The Consumer Financial Protection Bureau (“CFPB”) issued a proposed rule last week addressing the “Registry of Supervised Nonbanks that Use Form Contracts to Impose Terms and Conditions that Seek to Waive or Limit Consumer...more
On December 12th, the CFPB proposed to establish a registration system to catalog regulatory actions involving non-bank providers of consumer financial products and services brought by federal and state regulators. The...more
With the rapid rise of nonbank financial product and service companies in an everchanging marketplace, there is growing concern that nonbanks will evade federal oversight. To keep pace with these changes, the Consumer...more
The Federal Trade Commission (FTC) issued a Final Rule on October 27, 2021, amending the Standards for Safeguarding Customer Information, known as “the Safeguards Rule,” under the Gramm-Leach-Bliley Act, which is applicable...more
Senator Chris Van Hollen (D-MD) introduced a Congressional Review Act (CRA) resolution of disapproval on March 26 that would invalidate the Office of the Comptroller of the Currency’s (OCC’s) true lender final rule. ...more
Recently, seven states (New York, California, Colorado, Massachusetts, New Jersey, Minnesota, and North Carolina) and the District of Columbia filed suit in the Southern District of New York against the Office of the...more
I was only 9 years old when Jan and Dean in 1963 released their hit song “Dead Man’s Curve.” I thought about this song when I read the Conference of State Bank Supervisors’ (“CSBS”) Proposed Regulatory Prudential Standards...more
Should US state nonbank mortgage servicers be subject to “safety and soundness” standards of the type imposed by federal law on insured depository institutions, even though the nonbanks do not solicit and hold customer funds...more
The Office of the Comptroller of the Currency (OCC) issued a final rule on October 27 that determines when a national bank or federal savings association (bank) makes a loan and is the “true lender” in the context of a...more
Less than two months after issuing its final “Madden fix” rule, the OCC has now issued a proposed rule to address when a national bank or federal savings association should be considered the “true lender” in the context of a...more
The Department of Defense announced in its Fall 2019 rulemaking agenda that it is engaged in proposed rulemaking to amend its Military Lending Act (MLA) regulations, apparently in order to allow non-bank creditors to provide...more
Last Friday, the White House asked the SEC to “consider eliminating requirements that publicly traded companies post quarterly earnings reports.” Such disclosures, however, are required by federal securities law, so they’re...more
Europe’s much-ballyhooed (and feared) General Data Protection Regulation (“GDPR”) officially goes into effect today. Here’s a look at the mad dash across all sectors (and outside of the EU) to comply....more