Happy post-election, post-socially-distanced Thanksgiving, and pre-New Year’s newsletter. Banks, non-banks, and FinTechs can look forward to eight days of announcements from the Biden transition team with their latkes and...more
12/11/2020
/ Arbitration ,
Banking Sector ,
Bitcoin ,
BSA/AML ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Data Breach ,
Debt Collection ,
Fair Credit Reporting Act (FCRA) ,
Fair Lending ,
Federal Savings Associations ,
Financial Services Industry ,
FinCEN ,
FinTech ,
FRB ,
Main Street Lending Programs ,
Mobile Payments ,
OCC ,
Private Attorneys General Act (PAGA) ,
SBA ,
TCPA ,
Third-Party Service Provider
We join the nation in mourning the passing of Supreme Court Justice Ruth Bader Ginsburg. Over her 20-year career before appointment to the D.C. circuit court, Justice Ginsburg fought for equal rights in the workplace, among...more
10/16/2020
/ Arbitration ,
BSA/AML ,
California Consumer Privacy Act (CCPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
CRA ,
Credit Cards ,
Cybersecurity ,
ECOA ,
Fair Lending ,
FDIC ,
FFIEC ,
Financial Institutions ,
FinCEN ,
FRB ,
Governor Newsom ,
Interim Final Rules (IFR) ,
Main Street Lending Programs ,
OCC ,
Public Assistance ,
Ruth Bader Ginsberg ,
Safe Harbors ,
SBREFA ,
TCPA ,
Underwriting ,
Volcker Rule
Is it just us or does March 4 — the date of our last issue — feel like a million years ago? Like you, and not necessarily in this order, we have been: doing our work; keeping up with COVID-19-related laws, guidance, and...more
7/15/2020
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Arbitration ,
Auto-Dialed Calls ,
BSA/AML ,
CARES Act ,
Consent Order ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
CRA ,
Dodd-Frank ,
E-SIGN ,
Fair Lending ,
FASB ,
FDIC ,
Federal Reserve ,
FinCEN ,
FinTech ,
HMDA ,
Interim Final Rules (IFR) ,
Money Market Mutual Fund Liquidity Facility (MMLF) ,
OCC ,
Paycheck Protection Program Lending Facility (PPPLF) ,
Popular ,
Remittance Transfer Rule ,
Request For Information ,
RESPA ,
SPVs ,
TCPA ,
Volcker Rule
Punxsutawney Phil didn’t see his shadow, so we’re expecting an early spring. Maybe that’s why mini-CFPBs are sprouting or expanding on both coasts. Governor Cuomo announced several key measures impacting financial services...more
The holidays came early for financial institutions when the Supreme Court agreed to hear a challenge to the constitutionality of the CFPB. We can expect fireworks in the New Year as two experienced Supreme Court practitioners...more
We start this issue with a feeling of déjà vu all over again. Decisions made during the mortgage crisis are back in the news with a powerhouse legal ruling and the Treasury’s initial thinking on how to turn back time. First,...more
9/12/2019
/ Appeals ,
Arbitration ,
BSA/AML ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Fair Credit Reporting Act (FCRA) ,
Fair Lending ,
FDIC ,
Federal Trade Commission (FTC) ,
Financial Services Industry ,
FinCEN ,
GAO ,
HUD ,
Libor ,
Money Laundering ,
No-Action Letters ,
Reporting Requirements ,
Secured Overnight Funding Rate (SOFR) ,
Securities and Exchange Commission (SEC) ,
SHIELD Act ,
TCPA ,
Volcker Rule
The fireworks have started early this year. On May 2, a federal court in New York rejected the OCC’s motion to dismiss the lawsuit brought by the NY DFS challenging the OCC’s fintech charter. The decision has something for...more
6/18/2019
/ Appeals ,
Arbitration ,
BSA/AML ,
Consumer Financial Protection Bureau (CFPB) ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
OCC ,
TCPA ,
UDAP