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In early March, nearly a year and a half after it was initially proposed, the Massachusetts Attorney General's Office finalized the Commonwealth's "junk fee" regulation (the "Final Rule") while simultaneously issuing a...more
CFPB Imposes $5 Cap on Overdraft Fees Charged by Large Banks - The CFPB has adopted a final rule capping overdraft fees at $5 for banks and other depository institutions with more than $10 billion in assets (covered...more
The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more
Introduction - On May 17, 2022, the Board of Directors of the Federal Deposit Insurance Corporation (“FDIC”) adopted a final rule (“Rule”) setting forth its procedures for investigating and enforcing false advertising,...more
Federal Banking Agencies Issue CRA Modernization Proposal The federal banking agencies have jointly issued a proposed rule that would modernize their regulations that implement the Community Reinvestment Act (the “CRA”). The...more
Federal Banking Agencies Issue New Guidance on Managing the LIBOR Transition - The member agencies of the Federal Financial Institutions Examination Council (“FFIEC”) have issued joint guidance for banking organizations...more
In the News. The Consumer Financial Protection Bureau (CFPB) granted a no-action letter (NAL) regarding a proposed small-dollar credit product and sought comment on the CFPB’s plan to study how consumers locate, comprehend...more
SEC Charges Trust Company with Operating Unregistered Investment Companies and Failing to Register Securities Offerings. On September 30, the Securities and Exchange Commission (SEC) announced it had settled charges with...more
In This Issue. The Securities and Exchange Commission (SEC) adopted amendments to its exemptive applications procedures under the Investment Company Act of 1940, as amended (the 1940 Act) and proposed to amend Form 13F to...more
In This Issue. The Small Business Administration (SBA) provided guidance on a borrower’s good faith certification on the necessity of Paycheck Protection Program (PPP) loan requests, announcing a safe harbor regarding this...more
In This Issue. Federal financial regulators brought January to an impactful conclusion last week. On the morning of January 30, five federal financial regulators issued a proposed rule that would fundamentally modify the...more