The staff of the SEC’s Divisions of Trading and Markets, Investment Management, and Corporation Finance have updated guidance on the SEC’s final rule implementing section 13 of the Bank Holding Company Act of 1956 (“BHC Act”), commonly referred to as the Volcker Rule. In the new FAQs the staff advises... Read More
On March 2, 2016, the Consumer Financial Protection Bureau (CFPB) announced its first data security related enforcement action against online payment systems company Dwolla, Inc. Dwolla, Inc., operates an online payment system that involves the collection and storage of consumers’ sensitive personal information, including names, addresses, dates of birth, telephone... Read More
On March 1, 2016, the Consumer Financial Protection Bureau (CFPB) released its latest Monthly Complaint Report for February 2016, which provides an overview of three-month trends in consumer complaints. This Monthly Report also highlights consumer complaints related to prepaid products and complaints from the Houston, Texas metro area. Prepaid Product... Read More
On February 23, 2015, the Consumer Financial Protection Bureau (CFPB) announced two separate enforcement actions against Citibank, N.A., its affiliates, and two debt collection law firms, for alleged illegal debt sales and debt collection practices. Debt Sales Enforcement Action In the first enforcement action, the CFPB alleges that Citibank, N.A.,... Read More
On February 18, 2016, Director Richard Cordray of the Consumer Financial Protection Bureau (CFPB) gave a speech at the American Constitution Society, in which he repeatedly attacked arbitration provisions found in consumer agreements and set the stage for CFPB rulemaking that will likely greatly restrict the use of arbitration provisions... Read More
On February 18, 2016, the Consumer Financial Protection Bureau (CFPB) finalized a policy that establishes a process for companies developing financial products to apply for a statement from the CFPB, known as a “no-action letter,” regarding the regulatory impact of the proposed product. According to the CFPB, [t]he new policy... Read More
On February 2, 2016, the Consumer Financial Protection Bureau (CFPB) and the Department of Justice (DOJ) announced a joint enforcement action against indirect auto lender Toyota Motor Credit Corporation (Toyota Motor Credit) for alleged discriminatory lending practices in violation of the Equal Credit Opportunity Act (ECOA). The CFPB and DOJ... Read More
On January 20, 2016, Republican members of the House of Representatives’ Financial Services Committee issued a report titled Unsafe at Any Bureaucracy, Part II: How the Bureau of Consumer Financial Protection Removed Anti-Fraud Safeguards to Achieve Political Goals, which criticizes the Consumer Financial Protection Bureau (CFPB) for its actions following... Read More
On January 28, 2016, the Consumer Financial Protection Bureau (CFPB) released its latest Monthly Complaint Report for December 2015, which provides an overview of three-month trends in consumer complaints. This Monthly Report highlights consumer complaints related to “other financial service,” such as debt settlement, check cashing, money orders, and credit... Read More
The Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency issued an advisory to indicate their support for the principles and expectations set forth in Parts 1 and 2, respectively, of the Basel Committee on Banking Supervision’s... Read More