Understanding Scope of Practice
Evolving State Supervision: Issues Arising from State Qualification Standards and 'SAFE' Act Licensing, and Coordination with the CFPB
The Consumer Financial Protection Bureau (CFPB) released a procedural rule updating its supervisory process for institutions seeking to appeal a compliance rating or an adverse finding. Although the appeals process remains...more
Regulatory Developments - Federal Reserve Announces Results From the Review of the Supervision and Regulation of SVB - On April 28, the Federal Reserve released its report analyzing SVB’s failure (Report). The Report...more
On November 16, 2022, the Department of Treasury (“Treasury”) issued a report titled “Assessing the Impact of New Entrant Non-bank Firms on Competition in Consumer Finance Markets” (“Treasury Report”), which, among other...more
In this Issue. The Financial Industry Regulatory Authority (FINRA) issued a reminder about chief compliance officer (CCO) supervisory liability under FINRA Rule 3110 (Rule 3110); and the Consumer Financial Protection Bureau...more
Federal Banking Agencies Issue New Guidance on Managing the LIBOR Transition - The member agencies of the Federal Financial Institutions Examination Council (“FFIEC”) have issued joint guidance for banking organizations...more
The Consumer Financial Protection Bureau (CFPB, or the Bureau) has announced major changes to its organizational structure, placing enforcement operations under the effective control of supervision. If finalized, this will be...more
SEC Charges Trust Company with Operating Unregistered Investment Companies and Failing to Register Securities Offerings. On September 30, the Securities and Exchange Commission (SEC) announced it had settled charges with...more
“Supervisory guidance does not have the force and effect of law, and the agencies do not take enforcement actions based on supervisory guidance.” On September 11, 2018, the Bureau of the Consumer Financial Protection,...more
KISS. An acronym first utilized in military equipment design in the 1960’s, “Keep it Simple Stupid.” Litigators rely on KISS in formulating trial themes and presentations to juries....more
Notwithstanding the venerable status of the attorney client privilege and the important purposes it serves, the federal banking regulators and the Consumer Financial Protection Bureau have taken the position that they have...more
On January 27, 2015, the Consumer Financial Protection Bureau (“CFPB”) issued a compliance bulletin reminding supervised financial institutions (including large depository institutions, credit unions and their affiliates,...more
In his prepared remarks for an appearance last month at the Exchequer Club, Consumer Financial Protection Bureau Deputy Director Steven Antonakes discussed the CFPB’s risk-based approach to supervision. (The Exchequer Club’s...more
In a new compliance bulletin (2015-01), the CFPB reminds supervised financial institutions, including nonbanks, of their obligations regarding the disclosure of confidential supervisory information (CSI)....more
This will be a busy year at the Consumer Financial Protection Bureau (CFPB), and that certainly means it will be a busy year for financial institutions as well. In addition to exercising its supervisory and enforcement...more
oin Pepper Hamilton LLP, the Conference of State Bank Supervisors (CSBS) and RECOVCO Mortgage for an engaging discussion about important recent trends involving state supervision as states shift an ever greater amount of...more
In This Presentation: - Events That Changed Our World; And Yours Too! - Current Issues in Licensing - State Coordination With CFPB - The Path to Coordination - Responsibilities of the SCC ...more