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Consumer Financial Products Disclosure Requirements Banking Sector

Hogan Lovells

UK Consumer Duty rule review: FCA sets out ‘targeted steps’ to simplify requirements for firms

Hogan Lovells on

Following feedback to its July 2024 Call for Input (CfI) on placing greater reliance on the Consumer Duty instead of specific rules and guidance, the FCA won’t be carrying out a wholesale Handbook review. It has instead...more

Orrick, Herrington & Sutcliffe LLP

FDIC fines bank $650K for alleged unfair and deceptive acts

On January 31, the FDIC publicly announced its order for a bank in Sandy, Utah, to pay a civil money penalty of $650,000 due to allegations of deceptive acts and unfair practices. ...more

Orrick, Herrington & Sutcliffe LLP

New York Governor Hochul proposes new financial protections

On January 14, Governor Kathy Hochul announced new proposals to protect New York consumers as part of her 2025 State of the State. Her proposals included legislation to: (i) combat algorithmic price discrimination by...more

Nutter McClennen & Fish LLP

Nutter Bank Report: April 2024

The CFPB has issued a policy statement that provides an analytical framework for identifying what constitutes an abusive act or practice under the Consumer Financial Protection Act of 2010 (CFPA). The new guidance published...more

Goodwin

CFPB Launches New Initiative Focused on Rural Communities

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In This Issue. The Consumer Financial Protection Bureau (CFPB) announced a new initiative focused on financial issues faced by rural communities and also updated its examination procedures to cover unfair discrimination; the...more

Sheppard Mullin Richter & Hampton LLP

Consumer Fees Find Themselves in the Crosshairs: The CFPB Seeks Public Input on Alleged “Junk Fees” in the Consumer Financial...

The Consumer Financial Protection Bureau (“CFPB”) has continued to ratchet up its regulatory scrutiny over the consumer financial services market. On January 26, 2022, the CFPB published an initiative seeking public input on...more

Goodwin

CFPB To Revisit Trump-Era QM Final Rules

Goodwin on

In this Issue. The Consumer Financial Protection Bureau (CFPB) issued a statement announcing its intention to revisit Trump-era qualified mortgage (QM) final rules; the Biden Administration announced changes to the Small...more

Goodwin

OCC Proposes Rules for CRA Benchmarks and Fair Access

Goodwin on

In the News. The Office of the Comptroller of the Currency (OCC) issued a long-awaited rule seeking comment on its proposed approach to determine the Community Reinvestment Act (CRA) evaluation measure benchmarks, retail...more

Goodwin

SEC Adopts Broad Exempt Offering Reforms

Goodwin on

In the News. The Securities and Exchange Commission (SEC) adopted broad exempt offering reforms; the Department of Labor (DOL) finalized a rule, with significant revisions from the original proposal, on ESG investments; the...more

Ballard Spahr LLP

CFPB proposes revisions to trial disclosure policy

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The CFPB is proposing significant revisions to its “Policy to Encourage Trial Disclosure Programs” (TDP Policy), which sets forth the Bureau’s standards and procedures for exempting individual companies, on a case-by-case...more

Ballard Spahr LLP

CA on the verge of requiring commercial finance disclosures

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It appears likely that California Governor Jerry Brown will sign a bill passed on August 31 by the state’s Senate, Senate Bill 1235, which would create consumer-style disclosure requirements for certain commercial loans and...more

Ballard Spahr LLP

Education Dept. says state student loan servicing laws are preempted

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In response to the wave of new state student loan servicing laws and enforcement activity, the U.S. Department of Education has published an interpretation emphasizing that the Higher Education Act (HEA) preempts state...more

Jones Day

The European Securitisation Regulation: The Countdown has Begun....

Jones Day on

Draft Technical Standards Published for Consultation by the European Supervisory Authorities—An Update and Overview - Regulation (EU) 2017/2402, which is known as the "Securitisation Regulation" and lays down a general...more

Ballard Spahr LLP

House Passes Bill to Amend TRID Rule Disclosures

Ballard Spahr LLP on

On February 14, 2018, the United States House of Representatives passed the TRID Improvement Act of 2017, H.R. 3978, by a vote of 245 to 171. The bill would amend the manner in which title insurance premiums are disclosed...more

Ballard Spahr LLP

CFPB releases report on college credit card agreements

Ballard Spahr LLP on

The CFPB released its sixth annual report to Congress on college credit card agreements.  The annual report is mandated by the CARD Act. ...more

Ballard Spahr LLP

CFPB withdraws request to OMB to conduct online debt collection survey

Ballard Spahr LLP on

The CFPB has withdrawn its request to OMB to conduct an online survey of 8,000 individuals as part of its research on debt collection disclosures. Last month, the CFPB published a notice in the Federal Register that it was...more

Ballard Spahr LLP

Fed issues consent order for bank’s alleged deceptive practices involving balance transfer credit cards

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The Federal Reserve Board announced that it had issued a Consent Order against Mid America Bank and Trust Company (Bank) for alleged deceptive marketing practices in violation of section 5 of the FTC Act related to balance...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

SEC Proposes Rules to Implement FAST Act Mandate to Modernize and Simplify Disclosure - On October 11, 2017, the Securities and Exchange Commission (SEC) proposed amendments "to modernize and simplify disclosure...more

Carlton Fields

Real Property, Financial Services, & Title Insurance Update: Weeks Ending October 6 & 13, 2017

Carlton Fields on

REAL PROPERTY UPDATE FINANCIAL SERVICES UPDATE - Ad Valorem Taxes: land lease holders are considered equitable owners of land for tax purposes if land lease renews automatically and is perpetual; owners of condominium...more

Ballard Spahr LLP

CFPB proposes off-balanced approach to public disclosure of HMDA data

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In October 2015, the CFPB adopted significant changes to the rules under the Home Mortgage Disclosure Act (HMDA). Among the changes, the items of information to be collected and reported under HMDA are greatly expanded, with...more

Ballard Spahr LLP

Guidance from the OCC to banks regarding higher loan-to-value loan programs

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On August 21, 2017, the Office of the Comptroller of the Currency (OCC) published Bulletin 2017-28 regarding higher-loan-to-value (LTV) lending programs (the “Bulletin”). Recognizing the need for further revitalization...more

Ballard Spahr LLP

CFPB Adopts TRID Rule Amendments and Proposes to Address Black Hole Issue

Ballard Spahr LLP on

As we reported previously, the Consumer Financial Protection Bureau (CFPB) recently issued long-awaited amendments to the Truth in Lending Act (TILA)/Real Estate Settlement Procedures Act (RESPA) Integrated Disclosure (TRID)...more

Ballard Spahr LLP

NJ Assembly contemplates harsh restrictions on prepaid accounts

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The New Jersey Legislature is considering a law to restrict prepaid-account fees. Assembly Bill 4965 ( the NJ Bill) seeks to impose fee constraints, disclosure mandates, and limits on consumer liability for unauthorized...more

Ballard Spahr LLP

Propoposed Bill Would Significantly Expand MLA Disclosure Requirements

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We recently reported on a bill introduced in the House of Representatives by Congressman Dan Kildee (D-Michigan) that would amend the Military Lending Act (“MLA”) to require that creditors provide additional disclosures to...more

Ballard Spahr LLP

CFPB to seek OMB approval of survey on debt collection disclosures

Ballard Spahr LLP on

In a notice published earlier this week in the Federal Register, the CFPB announced that it plans to seek OMB approval to conduct an online survey of approximately 8,000 individuals as part of its research on debt collection...more

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