Recent initiatives by the Consumer Financial Protection Bureau (“CFPB” or Bureau) to dramatically expand its regulation of small business lending present a confluence of concerns to industry participants. These initiatives...more
On September 24, 2015, the CFPB and DOJ announced a joint action against Hudson City Savings Bank for allegedly discriminatory redlining practices from 2009 through 2013 in certain neighborhoods in New York, New Jersey,...more
9/29/2015
/ Banking Sector ,
Civil Monetary Penalty ,
Community Reinvestment Act ,
Compliance ,
Consumer Financial Protection Bureau (CFPB) ,
Department of Justice (DOJ) ,
Discriminatory Lending Practices ,
ECOA ,
Enforcement Actions ,
Fair Housing Act (FHA) ,
Fair Lending ,
HMDA ,
Mortgages ,
Race Discrimination ,
Redlining ,
Subsidies ,
Training Requirements
Not long after taking action against American Honda Finance Corporation under the disparate impact doctrine for allegedly discriminatory auto loan pricing, the CFPB has struck again—this time reportedly referring Santander...more
Just over 18 months after bringing a disparate impact-based ECOA case against Ally Financial (“Ally”) for discriminatory auto loan pricing, the CFPB has struck again—this time taking action against American Honda Finance...more
7/16/2015
/ Automotive Industry ,
Automotive Loans ,
Car Dealerships ,
Civil Monetary Penalty ,
Consent Order ,
Consumer Financial Protection Bureau (CFPB) ,
Discriminatory Lending Practices ,
Disparate Impact ,
ECOA ,
Enforcement Actions ,
Honda ,
Markups ,
Non-Bank Lenders ,
SCOTUS ,
Texas Dept of Housing v Inclusive Communities
Break out the short shorts everybody: it’s summer! We know you could use a palate cleanser between the 50 Shades novels and Game of Thrones wikis you’re reading on the beach. Supervisory Haiku-lights to the rescue! The Summer...more
6/30/2015
/ Chief Compliance Officers ,
Compliance ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Reporting Agencies ,
Credit Reports ,
Debt Collection ,
Debtor-Creditor ,
ECOA ,
Fair Credit Reporting Act (FCRA) ,
Housing Choice Vouchers ,
HUD ,
Mortgage Lenders ,
Mortgages ,
Regulation V ,
Regulation X ,
Section 8
On March 2, 2015, the Supreme Court of the United States granted certiorari in Hawkins v. Cmty. Bank of Raymore, 761 F.3d 937 (8th Cir. 2014), cert. granted, No. 14-520, 2015 U.S. LEXIS 1635 (U.S. Mar. 2, 2015)—on appeal from...more
This will be a busy year at the Consumer Financial Protection Bureau (CFPB), and that certainly means it will be a busy year for financial institutions as well.
In addition to exercising its supervisory and enforcement...more
1/26/2015
/ Automotive Loans ,
Banking Sector ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Debt Collection ,
ECOA ,
Financial Institutions ,
HMDA ,
Integrated Disclosures ,
Mortgage Lenders ,
Mortgages ,
Prepaid Payment Products ,
Proposed Regulation ,
Regulation C ,
RESPA ,
Supervision ,
Truth in Lending Act (TILA) ,
UDAAP