The Federal Trade Commission's (FTC) recent report, Big Data: A Tool for Inclusion or Exclusion?, released on January 6, warns businesses engaged in big data analytics that the practice poses liability risks. While the FTC...more
On December 17, 2015, the Office of the Comptroller of the Currency (OCC) proposed guidelines establishing enforceable standards for recovery planning by certain large national banks, federal savings associations and insured...more
The New York Department of Financial Services has issued a proposed regulation that sets forth minimum requirements for anti-money laundering transaction monitoring systems and watch list filtering systems. The proposed...more
On November 4, 2015, a group of law enforcement authorities, led by the Federal Trade Commission (FTC or the Commission), announced Operation Collection Protection, a coordinated federal, state and local initiative aimed at...more
On October 15, 2015, the Consumer Financial Protection Bureau (CFPB) issued a final rule to implement amendments to the Home Mortgage Disclosure Act (HMDA) made by the Dodd-Frank Wall Street Reform and Consumer Protection...more
10/23/2015
/ Banking Sector ,
Consumer Financial Protection Bureau (CFPB) ,
Discrimination ,
Dodd-Frank ,
Final Rules ,
HMDA ,
Mortgage Lenders ,
Mortgage Servicers ,
Mortgages ,
Popular ,
Regulation C ,
Reporting Requirements
On October 7, 2015, the Consumer Financial Protection Bureau (“CFPB” or the “Bureau”) released an outline of proposals under consideration to ban class action waivers in contracts for consumer financial products and services....more
10/9/2015
/ Arbitration ,
Arbitration Agreements ,
Class Action ,
Class Action Arbitration Waivers ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Department of Defense (DOD) ,
Exclusions ,
Military Lending Act ,
Proposed Regulation ,
Richard Cordray ,
Rulemaking Process ,
SBREFA
The Financial Crimes Enforcement Network (FinCEN) has proposed long-expected regulations that would extend anti-money laundering (AML) requirements to federally registered investment advisers (RIA). The August 25, 2015...more
9/4/2015
/ Banking Examinations ,
Banks ,
Broker-Dealer ,
BSA/AML ,
Dodd-Frank ,
Due Diligence ,
Enforcement ,
Financial Institutions ,
FinCEN ,
Industry Examinations ,
Investment Adviser ,
Investment Funds ,
Private Investment Funds ,
Proposed Regulation ,
Public Comment ,
SAR
On July 21, 2015, the U.S. Department of Defense (“DOD”) announced the final rule amending the Military Lending Act’s (“MLA”) implementing regulations. The changes apply the MLA’s strict lending restrictions to consumer...more
7/23/2015
/ Banking Sector ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Contract Terms ,
Department of Defense (DOD) ,
Financial Institutions ,
Interest Rates ,
Loan Documentation ,
Mandatory Arbitration Clauses ,
Military Lending Act ,
Military Service Members ,
Regulation Z ,
Servicemembers Civil Relief Act (SCRA) ,
Truth in Lending Act (TILA)
On June 25, 2015, the US Supreme Court issued a decision in Texas Department of Housing and Community Affairs v. The Inclusive Communities Project, holding that disparate-impact claims are cognizable under the Fair Housing...more
For the first time in a decade, the Treasury Department has released its own anti–money laundering (AML) and terrorist financing Risk Assessments, which may both set a strategic framework for future AML regulatory...more
6/19/2015
/ AML/CFT ,
Anti-Money Laundering ,
Anti-Terrorism Financing ,
Banking Sector ,
Casinos ,
Corporate Counsel ,
Digital Currency ,
FATF ,
Financial Institutions ,
Prepaid Payment Products ,
Risk Assessment ,
Securities ,
U.S. Treasury
On June 10, 2015, the Consumer Financial Protection Bureau (CFPB) announced a final rule that will allow it to supervise larger nonbank automobile finance companies. Accompanying the rule, it also published the procedures...more
6/16/2015
/ Automotive Industry ,
Automotive Loans ,
Car Dealerships ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Covered Entities ,
Fair Credit Reporting Act (FCRA) ,
FDCPA ,
Final Rules ,
Non-Bank Lenders ,
Regulation B ,
Supervision ,
UDAAP