President Trump has signed a resolution nullifying the rule implementing the CFPB’s power to supervise large nonbank financial services providers of general-use digital consumer payment applications....more
This week, the Consumer Financial Protection Bureau (CFPB or Bureau) released a memo to staff outlining its new supervision and enforcement priorities for 2025....more
The CFPB is rescinding its existing enforcement and supervision priority documents, according to a memo sent to bureau staff by CFPB Chief Legal Officer Mark Paoletta....more
The CFPB has issued a final rule to supervise large nonbank financial services providers that offer general-use digital consumer payment applications such as digital wallets and peer-to-peer payment apps....more
On February 23, 2024, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) published an order establishing supervisory authority over a small-loan consumer finance company, using a Dodd-Frank Act provision that...more
The CFPB has revised its internal supervisory appeals process for institutions seeking to appeal a compliance rating or an adverse material finding. The revisions became effective immediately upon publication in the Federal...more
On February 16, 2024, the Consumer Financial Protection Bureau (CFPB) announced what it heralded as a significant update to its Supervisory Appeals Process. The first of its kind since 2015, this revision introduced a...more
As discussed, in a recent letter, the Chairman of the National Credit Union Administration (NCUA) outlined the agency’s supervisory priorities for 2024. In this post, we delve deeper into the area of consumer protection...more
On October 16 of last year, I reported that Eric Halperin, Enforcement Director of the CFPB, announced that the CFPB intended to substantially increase the number of enforcement staff by 50% and to create a 5th litigation...more
A complaint filed on July 20, 2023 in Minnesota federal court seeks declaratory and injunctive relief under the Administrative Procedures Act (APA) against defendants Federal Deposit Insurance Corporation (FDIC) and Chairman...more
Growing up in New England we both heard that there were three things you should never discuss in public. Politics and religion were two. The third could differ....more
On April 25, 2022, the Consumer Financial Protection Bureau (CFPB) announced plans to revitalize its authority to examine “nonbank” financial companies that pose risks to consumers. Though the CFPB has held this authority...more
The Consumer Financial Protection Bureau (“CFPB”) recently announced that it is going to exercise authority described as “dormant” to supervise nonbanks that are not otherwise subject to the CFPB’s supervision authority....more
In This Issue. President Biden signed a bill extending the Small Business Administration’s (SBA) Paycheck Protection Program (PPP) through May 31, 2021; the Consumer Financial Protection Bureau (CFPB) announced the rescission...more
The CFPB’s final rule on the role of supervisory guidance was published in last Friday’s Federal Register....more
In this Issue. In one of its first acts after being installed on January 20, the Biden Administration issued a regulatory freeze on new agency rules that have been adopted but are not yet effective; in one of its final acts...more
The CFPB, OCC, FDIC and NCUA have issued substantially similar final rules on the role of supervisory guidance. The final rules adopt the agencies’ proposals without substantive change....more
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
In response to a call for a rulemaking by two leading bank industry trade associations, the federal banking agencies have issued a proposed rule to codify an earlier interagency statement that their supervisory...more
Regulatory Announcements - CFPB Issues No Action Letter to Facilitate Consumer Access to Loans. The Consumer Financial Protection Bureau (CFPB) issued a No-Action Letter to Bank of America, N.A. on November 5 regarding...more
On July 16, 2020, the Consumer Financial Protection Bureau (“CFPB”) hosted a webinar outlining, for the first time, the CFPB’s supervisory and enforcement priorities in light of the coronavirus pandemic....more