In the last eight months, the Consumer Financial Protection Bureau (CFPB) has signaled its intent to expand its use of abusiveness theories in enforcement matters. In March, the CFPB rescinded the previous administration's...more
In July, we discussed the federal banking agencies' proposal to harmonize their respective risk management guidance. At the time, we highlighted three passages from the proposal that relate to the due diligence banking...more
Last week, the federal banking agencies—Federal Reserve Board (Board), Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC)—issued proposed interagency guidance ("Proposal") on...more