Takeaways for Banks from the CFPB’s Recent Consent Order on Garnishment Orders
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Recently, U.S. attorneys general from 32 states and territories authored a bipartisan letter urging Congress to advance the SAFER Banking Act of 2025, which would increase access to regulated banking and financial services...more
The CFPB has filed a complaint against Synapse Financial Technologies Inc, alleging that the company engaged in unfair acts and practices in violation of the Section 1036(a)(1)(B) of the CFPA by failing to maintain sufficient...more
Thirty-two attorneys general representing states, territories and Washington, D.C. are asking Congress to pass legislation to provide financial institutions a safe harbor if they provide services to marijuana-related...more
As an American living abroad, you may have experienced firsthand the challenges of finding a financial institution willing to work with you. Whether it’s for opening a bank account, investing in local markets, securing a...more
On October 7, the CFPB released the Fall edition of its Supervisory Highlights, “Special Edition Auto Finance,” focusing on the auto finance market. The report highlights various supervisory observations and enforcement...more
The FCA has published a report setting out its findings from follow-up work on payment account access and closures, together with the results of independent research on the experiences some of the most financially excluded...more
The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) amended the Cuban Assets Control Regulations (CACR), 31 CFR Part 515, to promote internet freedom in Cuba, support independent Cuban private-sector...more
Components of the U.S. Federal Reserve System recently prevailed in two lawsuits in which both plaintiffs – Custodia Bank and PayServices Bank – alleged the defendants were required to grant the plaintiffs’ master account...more
On April 15, the Minnesota House of Representatives passed the Commerce Policy Omnibus bill, which includes key provisions of the Minnesota Debt Fairness Act. Minnesota AG Keith Ellison supports this bill and celebrated its...more
One of the important components of the collateral package for a subscription finance facility is the lender’s perfected security interest in the fund’s bank deposit account into which the actual cash constituting the proceeds...more
On February 14, 2024, the Minnesota Bankers Association and Lake Central Bank (the “Plaintiffs”) filed their memorandum in opposition to the Federal Deposit Insurance Corporation’s (FDIC) motion to dismiss their challenge to...more
On November 15, the CFPB announced a consent order against a Chicago-based small-dollar lender for allegedly violating a 2019 order and by independently violating the CFPA. According to the 2019 consent order, the respondent...more
In this month's article, we share some of our top "bites" for the prior month covered during the May 2023 webinar....more
The Consumer Financial Protection Bureau (CFPB) warned banks that unilaterally re-opening consumer accounts after account closure could constitute an unfair act or practice and the Securities and Exchange Commission’s (SEC)...more
Last Friday, the Federal Reserve Board (“FRB”) and Federal Deposit Insurance Corporation (“FDIC”) released reports evaluating their supervision of the failed Silicon Valley Bank (“SVB”) and Signature Bank (“Signature”),...more
On March 10, 2023, Silicon Valley Bank (SVB) was closed by the California Department of Financial Protection & Innovation, with the Federal Deposit Insurance Corporation (FDIC) appointed as receiver....more
On July 28, 2022, the Consumer Financial Protection Bureau (CFPB) issued a Consent Order against a large bank (the Bank), claiming that the Bank created sales pressure on its employees that encouraged employees to...more
Last week, six bank trade associations, including the Bank Policy Institute and the American Bankers Association, submitted a joint comment letter on the Federal Reserve’s re-proposed Guidelines for access to Fed accounts and...more
On March 8, the Federal Register published the Federal Reserve Board’s supplemental notice and request for comment on updates to its proposed guidelines for Federal Reserve Banks to utilize in evaluating requests for access...more
In Carol Tims v. LGE Community Credit Union, the Eleventh Circuit Court of Appeals held that a credit union’s account agreement with one of its customers was ambiguous about which account balance calculation the bank would...more
History may view 2018 as a pivotal year for marijuana legalization. Although the year started with then U.S. Attorney General Jeff Sessions creating a haze over the industry and legalization supporters when he rescinded...more
President Trump recently signed into law the Economic Growth, Regulatory Relief and Consumer Protection Act, which is already making waves in the financial sector for its repeal of certain Dodd-Frank provisions that were...more
The CFPB’s October 2017 complaint report, which the CFPB calls a “special edition” monthly complaint report, departs from the format of the CFPB’s standard monthly reports. (The CFPB’s June and July 2017 complaint reports...more
The CFPB has issued another report on checking account overdraft services, “Data Point: Frequent Overdrafts.” The new report represents the CFPB’s third report dealing with overdraft services. It previously issued a white...more
You know it is going to be a very bad day when, as a company’s Chief Executive Officer (CEO), you receive a letter asking the following, “Specifically, the committee should thoroughly examine this issue, including: How it is...more