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Financial Services Industry › Third-Party › Consumer Financial Products

Ballard Spahr LLP

Financial institutions may rely on third parties for Social Security, Taxpayer Identification Numbers

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Banks and credit unions may now rely on third parties to provide a consumer’s Social Security or Taxpayer Identification Number, according to an order issued by the FDIC, OCC and the NCUA with the consent of the Financial...more

K&L Gates LLP

Overview of the CFPB's Proposed Open Banking Rule and Final Industry Standard Setting Rule

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The financial services and banking industry landscape continues to evolve in the face of new and emerging technologies. This phenomenon is especially prevalent in the sharing of consumer data between financial institutions...more

Ballard Spahr LLP

FHA Seeks Comment on Third Party Originator Fraud With Short Comment Timeframe

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On June 17, 2024, FHA announced in draft Mortgage Letter 2024-12 a proposed revision to its Defect Taxonomy to clarify that fraud or material misrepresentation involving a sponsored Third-Party Originator (TPO) is a Tier 1...more

Troutman Pepper Locke

FDIC Announces Lineage Bank Consent Order Containing Third-Party Risk Management Program and Fintech Partnership Orders

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The Federal Deposit Insurance Corporation (FDIC) recently announced a consent order with Tennessee-based Lineage Bank containing orders relating to the bank’s third-party risk management program and its financial technology...more

Troutman Pepper Locke

Maryland Issues Guidance on Earned Wage Access Products

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On August 1, Maryland’s Office of Financial Regulation (OFR) issued guidance to “provide clarity on how [the OFR] views Earned Wage Access [EWA] products and to describe the requirements entities offering these products must...more

Sheppard Mullin Richter & Hampton LLP

CFPB Starts Year Seeking Comments on Proposals to Give Consumers Enhanced Control of Financial Data

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Recently, the CFPB released an outline of proposed measures related to the Bureau’s Dodd-Frank Section 1033 rulemaking efforts that would allow consumers to take control of their personal financial data and determine which...more

Ballard Spahr LLP

California legislature passes bills requiring licensure of debt collectors

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As part of California’s recent triad of consumer financial services legislation, including AB-1864, which creates the Department of Financial Protection and Innovation and the California Financial Protection Law, and AB-376,...more

Carlton Fields

Real Property, Financial Services, & Title Insurance Update: Week Ending February 7, 2020

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Real Property Update - Fraudulent Transfer: Real property that was worth less than mortgage encumbering it was not an asset per the plain language of section 726.102(2) and, therefore, could not support fraudulent transfer...more

Bricker Graydon LLP

FTC announces new and improved data security guidance

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On January 6, 2020, Andrew Smith, Director of the Federal Trade Commission (FTC) Bureau of Consumer Protection, announced three significant improvements to the FTC’s approach to data security enforcement cases....more

Ballard Spahr LLP

CA DBO concludes certain point-of-sale financing arrangements are loans, not credit sales

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On December 30, 2019, the California Department of Business Oversight (DBO) announced two actions regarding companies offering unregulated, point-of-sale financing to California residents.  In the first action,  the DBO...more

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