On behalf of the American Bankers Association (ABA) and the Consumer Bankers Association (CBA), Ballard Spahr has submitted an amicus brief to the United States Supreme Court in Coinbase, Inc., et al. v. Kramer, et al., No....more
Within a little less than four weeks after the publication on March 30, by the Consumer Financial Protection Bureau (CFPB) of its nearly 900-page final rule related to small business data collection (the Final Rule) mandated...more
US Senators Ask SoFi About Its Banking Law Compliance = “Four U.S. senators have signed a letter to SoFi Technologies CEO Anthony Noto expressing concerns about the online personal finance company and online bank’s digital...more
The results are in after the closing of a public comment period related to the Federal Deposit Insurance Corp.’s review of its bank merger policies. The request for information (RFI) included questions related to the agency’s...more
Though initially celebrated by many, the overturning of the CFPB’s arbitration rule could mean problems down the road for the financial services industry. The CFPB’s rule restricting arbitration clauses has been undone by...more
Earlier this month, the CFPB issued another report on checking account overdraft services, “Data Point: Frequent Overdrafts,” and four one-page prototype model forms to replace the current Regulation E model form for banks to...more
The American Bankers Association has submitted a comment letter in response to the CFPB’s request for information regarding consumer access to financial information. The ABA observes that while larger institutions have...more
The New York State Department of Financial Services (NYDFS) has come out strongly against an Office of the Comptroller of the Currency (OCC) proposal to grant national bank charters to financial technology (fintech)...more
At the meeting earlier this month of the American Bar Association’s Consumer Financial Services Committee in Carlsbad, CA, attention was given to an issue highlighted by the American Bankers Association in the comment letter...more
The Consumer Bankers Association and the American Bankers Association have submitted a comment letter setting forth their opposition to the CFPB’s proposed addition of a survey to the current complaint intake form....more
The Department of Defense (DoD) has issued an interpretive rule to assist the industry in complying with its July 2015 final rule amending the Military Lending Act’s implementing regulation. The much-anticipated guidance was...more
The American Bankers Association and the Consumer Bankers Association (the Associations) have sent a letter to the Office of Information and Regulatory Affairs (OIRA) (part of the Office of Management and Budget (OMB)) urging...more
The American Bankers Association has sent a comment letter to the CFPB challenging the Bureau’s use of the generic clearance process to conduct research in connection with its overdraft rulemaking. The letter was submitted...more
Companies involved in marketplace lending will be quite interested in the attendee list for the American Banker’s Marketplace Lending + Investing conference taking place this week in New York City. It indicates that 22...more
In a blog post earlier this week, Professor Jeff Sovern took issue with statements made by a legal expert that suggest an amendment to the Federal Arbitration Act would be necessary for the CFPB to ban class action waivers in...more
In response to the CFPB’s Request for Information seeking “best practices for normalizing relevant data” in the CFPB’s Consumer Complaint Database, the American Bankers Association has submitted a comment letter in which it...more
We have previously blogged about the comment letter concerning the CFPB’s March 10, 2015 Study on consumer arbitration that we submitted to the CFPB on behalf of the American Bankers Association, the Consumer Bankers...more
The American Bankers Association has sent a letter to the DOJ, Fed, OCC, FDIC, HUD and CFPB requesting confirmation “in interagency guidance, updated exam procedures, and where appropriate amended regulations that the...more
The Texas Bankers Association (TBA) announced on its website that it has filed a Freedom of Information Act (FOIA) Request with the CFPB to obtain all documentation the CFPB requested from bank software processors on the...more
On Wednesday, July 15, CFPB Director Richard Cordray appeared before the Senate Committee on Banking, Housing, & Urban Affairs to answer questions regarding the Bureau’s Semi-Annual Report to Congress and the President, which...more
The Dodd-Frank Wall Street Reform and Consumer Protection Act was enacted as a measure to promote financial stability and protection for consumers through increased regulation of nearly every aspect of the consumer finance...more
The American Bankers Association has submitted a 46-page comment letter on the CFPB’s proposed prepaid card rule. In the letter, the ABA makes the following key comments: Additional clarity is needed in the definition of the...more
The American Bankers Association has sent a letter to the CFPB requesting several clarifications to the mortgage servicing rules. The ABA asks the CFPB to make the clarifications part of “regulatory guidance (or regulatory...more