There is a tendency to think of consumer fraud and misrepresentation as intentional acts that deceive consumers into engaging in transactions that they would not otherwise engage in. A recent case demonstrates that the...more
On August 26, 2016, the Department of Defense (“DOD”) issued an interpretive rule (the “Interpretive Rule”) providing guidance on the DOD’s regulations implementing the Military Lending Act (“MLA”). That same day, we...more
9/16/2016
/ Credit Agreements ,
Credit Cards ,
Creditors ,
Department of Defense (DOD) ,
EFTs ,
Financial Institutions ,
Interpretive Rule ,
Loans ,
Military Annual Percentage Rates (MAPR) ,
Military Lending Act ,
Safe Harbors
BELTWAY -
Every Last Penny Counts -
Five federal banking agencies issued a Supervisory Bulletin titled “Interagency Guidance Regarding Deposit Reconciliation Practices” (the “Guidance”). The Guidance outlines...more
6/8/2016
/ Arbitration ,
Article III ,
CID ,
Civil Investigation Demand ,
Class Action Arbitration Waivers ,
Comptroller ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Credit ,
Customer Due Diligence (CDD) ,
Data Privacy ,
Data Security ,
Debt Collection ,
ECOA ,
FDCPA ,
Federal Reserve ,
Federal Trade Commission (FTC) ,
FFIEC ,
FHFA ,
Financial Institutions ,
FinCEN ,
FinTech ,
Hawkins v Community Bank of Raymore ,
Mobile Banking ,
Net Stable Funding Ratio (NSFR) ,
Online Marketplace Lending ,
Payday Loans ,
Payment Protection Insurance ,
PCI-DSS Standard ,
Preemption ,
RESPA ,
SCOTUS ,
Spokeo v Robins ,
Standing ,
Student Loans ,
TCPA ,
TILA-RESPA Integrated Disclosure Rule (TRID) ,
Truth in Lending Act (TILA) ,
UDAAP ,
Virtual Currency ,
Volcker Rule
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 May 18, 2016, five federal banking agencies—the Board of Governors of the Federal Reserve System (“Board”), the Consumer Financial Protection Bureau (“CFPB”), the Federal Deposit Insurance Corporation (“FDIC”), the...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