On June 10, 2015, six federal financial agencies (collectively, “Agencies”) jointly published a final Interagency Policy Statement, as required by Section 342 of the Dodd-Frank Act, outlining standards for assessing the...more
On June 3, 2015, the New York Department of Financial Services (“NYDFS”) issued a final rule regarding its “BitLicense” regulatory regime (“Final Rule”). The Final Rule follows an initial proposal from July 2014 and a revised...more
In This Issue:
- Arbitration Report
- Beltway Report
- Bureau Report
- Mobile & Emerging Payments Report
- Mortgage & Fair Lending Report
- Operations Report
- Preemption Report
-...more
6/9/2015
/ Arbitration Agreements ,
CashCall ,
Consumer Bankruptcy ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Creditors ,
Debt Collection ,
Debtor-Creditor ,
Fair Lending ,
Federal Arbitration Act ,
Mobile Payments ,
Mortgages ,
TCPA
There have been two recent virtual currency-related actions worthy of note: (1) the Financial Crimes Enforcement Network (“FinCEN”) announced its first civil enforcement action against a virtual currency exchanger, and (2)...more
On April 15, 2015, the Consumer Financial Protection Bureau (“CFPB”) announced a final rule (“Final Rule”) that suspends for one year the requirement under the Truth in Lending Act and implemented by Regulation Z that credit...more
At a field hearing in Richmond, Virginia on March 26, the Consumer Financial Protection Bureau (CFPB) outlined the proposal it is considering to regulate payday lending. The proposal would cover short- and long-term payday...more
On March 19, 2015, the Consumer Financial Protection Bureau (“CFPB”) published a notice and request for information (“2015 RFI”) regarding the impact of the Credit Card Accountability Responsibility and Disclosure Act of 2009...more
In This Issue:
- Beltway Report
- Bureau Report
- Mobile & Emerging Payments Report
- Mortgage & Fair Lending Report
- Operations Report
- Preemption Report
- Privacy...more
On February 26, 2015, the Consumer Financial Protection Bureau (“CFPB”) published a proposed rule (“Proposed Rule”) that would suspend for one year the requirement that credit card issuers submit their agreements to the CFPB...more
On February 4, 2015, the New York Department of Financial Services (“NYDFS”) issued for public comment a revised proposed rule to implement a “BitLicense” regulatory regime (the “2015 Proposal”). As discussed below, the 2015...more
In This Issue:
- Beltway Report
- Bureau Report
- Mobile & Emerging Payments Report
- Mortgage & Fair Lending Report
- Operations Report
- Preemption Report
- Privacy...more
12/19/2014
/ Arbitration ,
Banking Sector ,
Banks ,
Consumer Financial Products ,
Dodd-Frank ,
Fair Lending ,
Federal Reserve ,
Mobile Payments ,
Mortgages ,
Payment Systems ,
Privacy Laws ,
Regulation AA ,
Structured Financial Products ,
TCPA
On November 13, 2014, the Consumer Financial Protection Bureau (“CFPB”) issued a proposed rule to regulate prepaid accounts (the “Proposed Rule”). The Proposed Rule follows the CFPB’s May 2012 advance notice of proposed...more
Today, the Consumer Financial Protection Bureau (“CFPB”) issued its long-awaited proposed rule to further regulate prepaid card products (the “Proposed Rule”). The Proposed Rule was the topic of discussion at a field hearing...more
On October 27, 2014, the Financial Crimes Enforcement Network (“FinCEN”) issued two administrative rulings regarding virtual currency. The first administrative ruling concerns a proposed virtual currency trading and booking...more
In This Issue:
- Beltway Report
- Bureau Report
- Mobile and Emerging Payments Report
- Mortgage and Fair Lending Report
- Operations Report
- Preemption Report
- Privacy...more
9/18/2014
/ Banking Sector ,
Banks ,
Consumer Financial Protection Bureau (CFPB) ,
Data Breach ,
Debt Collection ,
Federal Reserve ,
Lending ,
Mortgages ,
OCC ,
Privacy Policy ,
RESPA ,
Robo-Signing ,
TCPA ,
Volcker Rule
Yesterday, the New York Department of Financial Services (“NYDFS”) issued a proposed rule for public comment setting forth a novel and comprehensive “BitLicense” regulatory scheme for entities engaged in “Virtual Currency...more
On June 26, 2014, the U.S. Government Accountability Office (“GAO”) released a report, entitled “Virtual Currencies: Emerging Regulatory, Law Enforcement, and Consumer Protection Challenges.” The report, delivered earlier to...more
7/8/2014
/ Consumer Financial Protection Bureau (CFPB) ,
Department of Homeland Security (DHS) ,
Department of Justice (DOJ) ,
GAO ,
Information Reports ,
IRS ,
Law Enforcement ,
Legislative Committees ,
Popular ,
Property Tax ,
Virtual Currency
Industry anticipation continues to grow as the Consumer Financial Protection Bureau (CFPB) announced that its general-purpose reloadable (GPR) prepaid card proposal will now be issued by the end of the summer. Although this...more
Yesterday, the Consumer Financial Protection Bureau (“CFPB”) released a request for information (“RFI”) concerning the use of mobile financial services, specifically among unbanked and underbanked consumers. The RFI was...more
In This Issue:
- Beltway Report
- Bureau Report
- Mobile Payments
- Mortgage and Fair Lending Report
- Operations Report
- Preemption Report
- Privacy Report
- Arbitration Report
- TCPA...more
6/9/2014
/ Banks ,
Cybersecurity ,
Data Protection ,
Encryption ,
Fair Lending ,
FDIC ,
FFIEC ,
Financial Regulatory Reform ,
Heartbleed ,
Mobile Payments ,
Mortgages ,
OCC ,
OIG ,
Popular ,
RESPA ,
Servicemembers Civil Relief Act (SCRA) ,
TCPA ,
Truth in Lending Act (TILA) ,
Volcker Rule
Earlier this year, the Board of Governors of the Federal Reserve System (“Board”) released a report on its third annual Survey of Consumers’ Use of Mobile Financial Services (the “2013 Survey”). The 2013 Survey are part of...more
In the wake of the financial crisis, federal and state regulators are increasingly taking action against individuals for alleged compliance lapses inside financial services companies, and recent reports indicate that...more
In the wake of the financial crisis, federal and state regulators are increasingly taking action against individuals for alleged compliance lapses inside financial services companies, and recent reports indicate that...more
On January 30, 2014, the Financial Crimes Enforcement Network (“FinCEN”) issued two administrative rulings that address the application of Bank Secrecy Act (“BSA”) regulations to convertible virtual currency-related...more
On January 23, 2014, the Consumer Financial Protection Bureau (“CFPB”) issued a proposed rule that would define which nonbank covered persons would be designated “larger participants” for purposes of the international money...more