On December 22, 2020, the Consumer Financial Protection Bureau (CFPB) announced that it had entered into a consent order with a national lender and originator of subprime auto loans over the company’s alleged violations of...more
In the News. The Office of the Comptroller of the Currency (OCC) finalized its “true lender” rule, which establishes that a national bank or federal savings association (bank) is the “true lender” of a loan if, as of the...more
10/29/2020
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Amended Rules ,
Bank Secrecy Act ,
Banking Sector ,
CFTC ,
Community Development Financial Institution (CDFI) ,
Comptroller ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Depository Institutions ,
Derivatives ,
FDCPA ,
FDIC ,
Federal Reserve ,
FHFA ,
Final Rules ,
Financial Institutions ,
Financial Records ,
Financial Services Industry ,
FinCEN ,
FinTech ,
Forbearance Agreements ,
Insured Depository Institutions ,
Inter-Bank Offered Rates (IBORs) ,
Investors ,
ISDA ,
Military Service Members ,
Mortgages ,
OCC ,
Private Investment Funds ,
Proposed Rules ,
Proxy Statements ,
Recordkeeping Requirements ,
Securities and Exchange Commission (SEC) ,
Shareholder Proposals ,
TILA-RESPA Integrated Disclosure Rule (TRID) ,
Travel Rule ,
True Lender ,
Truth in Lending Act (TILA)
On September 2, 2020, the Consumer Financial Protection Bureau (CFPB) announced it had entered into a consent order with a Delaware-based VA-mortgage lender, resolving allegations that the company had engaged in deceptive...more
On September 1, 2020, the Consumer Financial Protection Bureau (“CFPB”) announced that it had issued a consent order against a Maryland-based corporation offering VA-guaranteed loans in twelve states. According to the consent...more
On September 1, 2020, the Consumer Financial Protection Bureau (“CFPB”) announced that it had issued a consent order against a Miami-based lender based on its deceptive advertisements to service members and military veterans...more
In This Issue. The Office of the Comptroller of the Currency (OCC) released an advanced notice of proposed rulemaking seeking comments on several issues related to digital technology and innovation, as well as proposed...more
6/12/2020
/ Acquisitions ,
Advanced Notice of Proposed Rulemaking (ANPRM) ,
Amended Rules ,
Banking Sector ,
Comment Period ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
E-Signatures ,
Enforcement Actions ,
Federal Reserve ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
Financial Reporting ,
Financial Services Industry ,
Innovation ,
Libor ,
Main Street Lending Programs ,
OCC ,
Paycheck Protection Program Flexibility Act of 2020 (PPPFA) ,
Payday Loans ,
Public Comment ,
Restraining Orders ,
Securities and Exchange Commission (SEC) ,
Term Asset-Backed Securities Loan Facility (TALF)
In this Issue: Senate Votes to Expand Paycheck Protection Program; FHFA (Finally) Addresses Liquidity Concerns for Mortgage Servicers. Yesterday, the U.S. Senate unanimously passed legislation providing $484 billion in...more
4/24/2020
/ Banking Sector ,
Borrower Protection Programs ,
Borrowers ,
BSA/AML ,
CARES Act ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Fannie Mae ,
Federal Funding ,
Federal Reserve ,
FHFA ,
Final Rules ,
Financial Institutions ,
Financial Services Industry ,
Financial Stimulus ,
Freddie Mac ,
HMDA ,
Legislative Agendas ,
Lenders ,
Liquidity ,
Main Street Lending Programs ,
Mortgage Servicers ,
Paycheck Protection Program (PPP) ,
Regulatory Requirements ,
SBA ,
SBA Lending Programs ,
Small Business ,
Startups
On April 1, 2020, the Consumer Financial Protection Bureau (CFPB) announced that it had entered into a consent order with an installment-loan lender, resolving allegations that the lender violated the Consumer Financial...more
I’m Dreaming of . . . LIBOR Cessation and Transition. While many of us were enjoying the holiday season, federal and state financial regulators were focused on the transition away from the London Interbank Offered Rate...more
1/9/2020
/ Accredited Investors ,
CFTC ,
Consumer Financial Protection Bureau (CFPB) ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
Financial Services Industry ,
Libor ,
No-Action Letters ,
OCIE ,
Popular ,
Qualified Institutional Buyers ,
Secured Overnight Funding Rate (SOFR) ,
Securities and Exchange Commission (SEC) ,
Swaps
In This Issue. The Securities and Exchange Commission (SEC) issued a risk alert on investment adviser principal and agency cross trading compliance issues, published disclosure interpretations relating to the Inline XBRL...more
9/12/2019
/ Compliance ,
Consumer Financial Protection Bureau (CFPB) ,
Cross Trading ,
Cybersecurity ,
Debt Collectors ,
ESOP ,
FDCPA ,
FDIC ,
Federal Trade Commission (FTC) ,
FFIEC ,
Filing Fees ,
Financial Services Industry ,
Flood Insurance ,
Investment Adviser ,
OCIE ,
Proxy Voting Guidelines ,
Securities and Exchange Commission (SEC) ,
XBRL Filing Requirements
In This Issue. Federal banking regulators proposed the long-awaited “community bank leverage ratio,” which would exempt community banks with a leverage ratio of at least 9% from Basel III capital requirements; the Federal...more
11/29/2018
/ Antitrust Division ,
ATDS ,
Banking Sector ,
Banks ,
Basel III ,
Blockchain ,
CFIUS ,
Consumer Financial Protection Bureau (CFPB) ,
Cybersecurity ,
FASB ,
FDIC ,
FFIEC ,
FHFA ,
NYSE ,
Real Estate Development ,
Regulation CC ,
Regulation J ,
Regulation M ,
Regulation Z ,
Securities and Exchange Commission (SEC) ,
Servicemembers Civil Relief Act (SCRA) ,
Smaller Reporting Companies
Editor's Note -
First Half of 2018 Sees Significant Decline in Publicly Announced or Publicly Filed Enforcement Activity. During the first half of 2018, Enforcement Watch tracked 40 publicly announced or publicly filed...more
11/8/2018
/ Banking Sector ,
Consumer Financial Protection Bureau (CFPB) ,
Excessive Fees ,
FDIC ,
Federal Trade Commission (FTC) ,
Financial Services Industry ,
Investors ,
Securities and Exchange Commission (SEC) ,
Shareholders ,
SIFIs ,
TCPA
On October 24, 2018, the Consumer Financial Protection Bureau (“CFPB”) announced that it had entered into a Consent Order with a Tennessee-based small dollar lender, resolving allegations that the lender had committed...more
Editor's Note -
No Rest for the Regulators. While many in the financial services industry used the last few weeks of August to enjoy additional time with family and friends before the back-to-school crunch, federal...more
9/13/2018
/ Bank Holding Company ,
Banking Sector ,
Class Action ,
Community Reinvestment Act ,
Consumer Financial Protection Bureau (CFPB) ,
Digital Currency ,
Enforcement Actions ,
Filing Fees ,
FinCEN ,
HMDA ,
Interest Rates ,
Liquidity Coverage Ratio ,
Mortgages ,
OCC ,
Securities and Exchange Commission (SEC) ,
Summary Judgment ,
Volcker Rule
Regulatory Developments -
FinCEN Provides 90-Day Exceptive Relief From Beneficial Ownership Requirements for Certain Products and Services With Automatic Rollovers or Renewals -
On May 16, the Financial Crimes...more
5/24/2018
/ Anti-Money Laundering ,
Consumer Financial Protection Bureau (CFPB) ,
Federal Trade Commission (FTC) ,
Financial Industry Regulatory Authority (FINRA) ,
FinCEN ,
OCC ,
RESPA ,
Securities and Exchange Commission (SEC) ,
TCPA ,
TILA-RESPA Integrated Disclosure Rule (TRID) ,
Truth in Lending Act (TILA)
Editor's Note -
In This Issue. The Consumer Financial Protection Bureau (CFPB) published its Spring 2018 rulemaking agenda; the U.S. Department of Housing and Urban Development (HUD) announced that it will seek public...more
On February 2, 2018, the Board of Governors of the Federal Reserve System (the “Board”) announced that it would restrict the growth of a national bank based on its past consumer abuses and compliance failures and its need to...more
On November 8, 2017, the Consumer Financial Protection Bureau (“CFPB”) announced it filed suit in federal court in California against a national debt-settlement services provider and its CEO based on alleged violations of the...more
On September 8, a federal judge in California ordered a national mortgage services company to pay a $7.9 million civil penalty based on false or misleading marketing statements it allegedly made to consumers about its...more