CFPB's Policy Statement on Abusiveness (Part 2) - The Consumer Finance Podcast
Compliance Perspectives: Changes to the Physician Self-Referral and Anti-Kickback Rules
The UK Prudential Regulation Authority (PRA) has published a policy statement providing feedback to its consultation paper CP1/25 on the Financial Services Compensation Scheme (FSCS) Management Expenses Levy Limit for the...more
The Bank of England has published a statement of policy setting out its approach to determining commercially reasonable payments to clearing members whose contracts are subject to a statutory tear up in CCP resolution,...more
The Payment Systems Regulator has published a policy statement confirming the maximum level of Authorized Push Payment scam reimbursement. The statement follows the PSRs recent announcement confirming its decision to reduce...more
The U.K. Prudential Regulation Authority has published a policy statement on its approach to rule permissions and waivers. The policy statement provides feedback to responses the PRA received to CP3/24 published in January....more
The Federal Deposit Insurance Corp. and the Office of the Comptroller of the Currency recently announced proposals to update their approaches to evaluating bank mergers and other business combinations under the Bank Merger...more
The CFPB has issued a policy statement that provides an analytical framework for identifying what constitutes an abusive act or practice under the Consumer Financial Protection Act of 2010 (CFPA). The new guidance published...more
Volume 4, Issue 2, 2024 Welcome! Welcome to the second issue of Promissory Notes - our banking and finance e-newsletter - for 2024. Business today is characterized by relentless change. To assist our clients in navigating...more
On June 30, the Federal Reserve Board (“FRB”), Federal Deposit Insurance Corporation (“FDIC”), Office of the Comptroller of the Currency (“OCC”) and the National Credit Union Administration (“NCUA”) finalized their Policy...more
The Consumer Financial Protection Bureau (CFPB) released a second iteration of its Policy Statement on Abusive Acts and Practices (Policy Statement) on April 3, 2023, giving insight into its current thinking on the...more
Federal Reserve Issues Policy Statement on Section 9(13) of the Federal Reserve Act - On January 27, the Federal Reserve issued a policy statement interpreting section 9(13) of the Federal Reserve Act, which authorizes...more
Custodia Bank was denied Federal Reserve membership, while certain crypto principal activities are deemed presumptively not appropriate for member banks. On January 27, 2023, the Board of Governors of the Federal Reserve...more
On July 26, 2022, the Office of the Comptroller of the Currency (OCC) issued an update to its 2013 policy statement on minority depository institutions (MDIs). Changes to the policy statement include: (i) clarifying the...more
In This Issue. Several federal financial regulatory agencies updated their Spring 2021 regulatory agendas; the Consumer Financial Protection Bureau (CFPB) announced its intention to restart Military Lending Act examinations;...more
The Financial Crimes Enforcement Network (FinCEN) on June 30, 2021, issued national priorities for anti-money laundering (AML) and countering the financing of terrorism (CFT) policy (the Priorities), as required by the...more
Fed Issues Proposed Rule for New Instant Electronic Payment Service - FedNow The Federal Reserve has issued a proposed rule that would govern funds transfers over the Federal Reserve’s new 24x7x365 service that will...more
In the News. On the heels of a lawsuit challenging the Office of the Comptroller of the Currency’s (OCC) recently issued Madden fix/valid when made rule, eight state attorneys general filed suit challenging a similar rule...more
In This Issue. The Small Business Administration (SBA) provided guidance on a borrower’s good faith certification on the necessity of Paycheck Protection Program (PPP) loan requests, announcing a safe harbor regarding this...more
3 February - The European Banking Authority (“EBA”) published a report on the benchmarking of diversity practices in credit institutions and investment firms under the CRD IV Directive (2013/36/EC)....more
In This Issue. Federal banking agencies finalized an Interagency Policy Statement on Allowance for Credit Losses, which is intended to promote consistency in the interpretation and application of the current expected credit...more
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
In a Policy Statement effective on January 24, 2020, the CFPB addresses perceived uncertainty as to the scope and meaning of the abusiveness standard, and that the CFPB had in various enforcement actions asserted claims for...more
The U.K. Prudential Regulatory Authority has published a Policy Statement, revised reporting rules and a revised Supervisory Statement on the PRA's approach to supervising liquidity and funding risks (SS 25/15). The changes...more
On 7 June 2019, the Financial Conduct Authority (“FCA”) confirmed that it is introducing reforms in relation to the overdraft market, set out in its policy statement PS19/6. The aim of these reforms is to make overdrafts...more
In November 2016, with the election results confirmed, the banking industry was awash in hopes for a more lenient regulatory posture. To date, the industry has seen no reform. However, on March 14, 2018, the Senate passed and...more
Seyfarth Synopsis: The FDIC is accepting comments until March 9, 2018 on the proposed revisions to the Statement of Policy for Section 19 of the Federal Deposit Insurance Act; the FDIC is seeking, among other things, to...more