On April 25, 2023, the Federal Trade Commission (FTC), the Civil Rights Division of the U.S. Department of Justice (DOJ), the Consumer Financial Protection Bureau (CFPB), and the U.S. Equal Employment Opportunity Commission...more
On April 3, 2023, the Consumer Financial Protection Bureau ("CFPB" or the "Bureau") published a policy statement on abusiveness in the financial services marketplace. The statement summarizes actions taken by government...more
The Consumer Financial Protection Bureau (CFPB or Bureau), under Director Chopra, is moving toward placing new restrictions on fees for the late payment of credit card debts. The proposed rulemaking represents a continuation...more
Is my money safe? It's a question that we haven't heard very much in over twelve years.
Most businesses and people have no experience with troubled banks and potential bank failures....more
Key developments in the United States over the past several months have kicked the digital currency transformation discussion into high gear. After the President’s Working Group on Financial Markets’ November 2021 Report on...more
Our team is pleased to announce an important publication on crypto developments and future stablecoin regulation in the United States. Here we provide a brief overview of stablecoins, outline various risks and policy concerns...more
In July, we discussed the federal banking agencies' proposal to harmonize their respective risk management guidance. At the time, we highlighted three passages from the proposal that relate to the due diligence banking...more
Last week, the federal banking agencies—Federal Reserve Board (Board), Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC)—issued proposed interagency guidance ("Proposal") on...more
Approximately 22 percent of U.S. residents over the age of 5 speak a language other than English at home. Of those persons, approximately 37.6 percent have limited English proficiency (LEP), meaning they have a limited...more
California now has its own mini Consumer Financial Protection Bureau (CFPB). Although California is not the first state to create such an entity, the new regulator's resources and authority—not to mention the size of the...more
On April 9, 2020, the Federal Reserve Board of Governors announced several extraordinary measures to support the national economy during COVID-19. Among these is the Main Street Lending Program, which will enable up to $600...more
On May 6, 2019, the Ninth Circuit concluded that the CFPB is constitutionally structured. In CFPB v. Seila Law LLC, Seila Law argued that the CFPB’s structure violates the Constitution’s separation of powers doctrine because...more
Earlier this month, the Federal Deposit Insurance Corporation (FDIC) published a Request for Information (RFI) seeking public comment on issues related to small-dollar lending by FDIC-supervised financial institutions. ...more
Federal and state fair lending regulators are charting different courses for the future of “disparate impact” liability under the Equal Credit Opportunity Act and analogous state law....more