Consumer Finance Monitor Podcast Episode: Perspectives on Counseling on the Creation of Consumer Finance Products, with Guest Joseph Schuster, Managing Director and Senior Counsel, Goldman Sachs
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Smoother Sailing or Choppy Waters: What Lies Ahead for the 2022 D&O Market?
D&O in Brazil and Latin America
Regan Miller, RPLU on Cyber Risk
Traditional credit underwriting methods, which are generally based on credit reports, have not always successfully captured the full picture of a borrower’s ability to repay. It is estimated that more than 45 million US...more
Our discussion looks at the role of in-house and outside counsel in the development and launch of new consumer financial products. We first discuss the range of issues to be considered as part of the preliminary scoping...more
A&B ABstract: Three recent actions by the Consumer Financial Protection Bureau (“CFPB”), on consecutive days, highlights inconsistencies in the CFPB’s current approach to payday lending....more
The Bank of Israel recently published a draft directive on proper banking management. It details various provisions in favor of changing the conduct patterns of consumer credit providers toward their clients, both from the...more
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
In the News. The Board of Governors of the Federal Reserve System (Federal Reserve) proposed rules to modernize the regulations that implement the Community Reinvestment Act (CRA); the Conference of State Bank Supervisors...more
The Texas federal district court hearing the lawsuit filed by two trade groups challenging the CFPB’s 2017 final payday/auto title/high-rate installment loan rule (2017 Rule) has entered an order lifting the stay of lawsuit,...more
The Consumer Financial Protection Bureau (CFPB) issued a final rule on July 7, 2020 rescinding the mandatory ability to repay underwriting provisions on small dollar loans that it had previously announced under 12 C.F.R. §...more
In an opinion authored by Chief Justice Roberts (the “DACA Opinion”), the Supreme Court has concluded that the rescission of the DACA program by the U.S. Department of Homeland Security (DHS) was arbitrary and capricious and...more
In a new era of double-digit unemployment resulting from the COVID-19 pandemic, it may be tough for a mortgage lender to predict the amount and stability of someone’s income in order to determine qualification for a home...more
Mortgage loan brokers, correspondents and loan originators (“Originators”) who survived (or, in many cases, are still dealing with) the onslaught of “repurchase/indemnification” claims asserted by loan aggregators and...more
Focus areas included FCRA, Fair Lending, ancillary fees and services (such as lender placed flood insurance), TCPA, privacy and data security and other topics. Consumer Financial Protection Bureau’s Director Kathleen...more
On February 20, the Consumer Financial Protection Bureau (CFPB), South Carolina Department of Consumer Affairs, and Arkansas Attorney General’s Office announced? that they had filed a lawsuit in the U.S. District Court for...more
The OCC announced yesterday that it’s bringing enforcement actions against five former Wells Fargo bank executives as part of their alleged roles in the bank’s sales practices scandal. The agency further revealed that it’s...more
The OCC, Federal Reserve Board, FDIC, NCUA and CFPB have issued an “Interagency Statement on the Use of Alternative Data in Credit Underwriting.”...more
The Consumer Financial Protection Bureau made it clear that it will continue to target auto finance lenders as one of its top supervisory and enforcement priorities in the Fair Lending Report of the Bureau of Consumer...more
In February 2019, the CFPB released the highly anticipated revamp of its Payday Rule, reinforcing its more lenient attitude towards payday lenders. In light of the Bureau’s softer touch, as well as similar developments at the...more
The Consumer Financial Protection Bureau (CFPB) has issued highly anticipated proposed revisions to its final payday/auto title/high-rate installment loan rule that would rescind the rule's ability-to-repay provisions—which...more
Today February 6, 2019, the CFPB proposed amendments to its Payday, Vehicle Title, and Certain High-Costs Installment Loans Rule. As anticipated, the bureau is proposing to rescind the rule’s requirements that lenders make...more
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
For the first time since 2004, FINRA has proposed major amendments to its requirements that govern the terms of the underwriting arrangements for most public offerings of securities and mandate that such arrangements be...more
On May 18, 2016, the Consumer Financial Protection Bureau (CFPB) announced that it will hold a field hearing in Kansas City, Missouri, on June 2 regarding small-dollar lending, commonly referred to as payday lending. It is...more
Earlier this year, the CFPB filed a complaint in Atlanta federal district court targeting an alleged debt collection scam in which not only were the debt collectors named as defendants (Debt Collectors) but three companies...more