Developments concerning the enforceability and enforcement of the CTA came at a rapid clip last week. As things stand, the government may enforce the CTA pending a Texas court appeal in Smith v. U.S. Department of the...more
On April 17th, the CFPB issued a consent order to a for-profit training school alleging numerous violations of law related to its use if income share agreements (“ISAs”). According to the Bureau, BloomTech, Inc. (“BloomTech”)...more
4/29/2024
/ Consent Order ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Department of Financial Protection and Innovation (DFPI) ,
Educational Institutions ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
Financial Services Industry ,
Holder Rule ,
Income Share Agreements ,
Regulation Z ,
Regulatory Violations ,
Truth in Lending Act (TILA) ,
UDAAP ,
Unfair or Deceptive Trade Practices
In February 2024, the Federal Deposit Insurance Corporation (FDIC) entered into consent orders with two banks who partner with fintechs to offer “banking as a service” (BaaS) related to safety and soundness concerns relating...more
4/12/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banks ,
Consent Order ,
Customer Identification Program (CIP) ,
Enforcement Actions ,
FDIC ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
Money Laundering ,
Risk Management ,
Terrorist Financing ,
Third-Party ,
True Lender
Recently, the Industrial and Commercial Bank of China Ltd. (“ICBC”) entered into two consent orders. The first consent order is with the New York State Department of Financial Services (the “NYDFS”) for alleged deficiencies...more
2/8/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Books & Records ,
BSA/AML ,
Cease and Desist Orders ,
Compliance Management Systems ,
Confidential Supervisory Information ,
Consent Order ,
Disclosure Requirements ,
Enforcement Actions ,
Failure to Comply ,
Federal Reserve ,
Financial Crimes ,
Financial Institutions ,
Money Laundering ,
NYDFS ,
Office of Foreign Assets Control (OFAC) ,
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