Last month, the Federal Deposit Insurance Corporation (“FDIC”) took action against a bank for alleged unsafe or unsound banking practices. This, in and of itself, is not usual or newsworthy. What is unusual and newsworthy,...more
12/14/2023
/ Audits ,
Banks ,
Compliance ,
Consent Order ,
EFTA ,
Enforcement Actions ,
FDIC ,
FinTech ,
High Risk Sectors ,
RESPA ,
Risk Management ,
Third-Party ,
Training ,
Truth in Lending Act (TILA)
On November 1, 2023, the Office of the Comptroller of the Currency (OCC) published a revised interagency examination procedure to address updates to the federal Telephone Consumer Protection Act (TCPA).
Although TCPA...more
11/16/2023
/ Advertising ,
Auto-Dialed Calls ,
Carve Out Provisions ,
Compliance ,
Data Breach ,
Debt Collectors ,
Enforcement Actions ,
Examination Procedures ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
Fraud ,
OCC ,
Security Breach ,
Solicitation ,
TCPA ,
Telemarketing ,
Training
On March 30, 2023, the Consumer Financial Protection Bureau (“CFPB”) (finally) issued its Final Rule on Section 1071 — only one day ahead of the court-ordered deadline to do so. This means that covered financial institutions...more
On Tuesday, March 15, President Joe Biden signed into law a $1.5 trillion government funding bill that included new legislation mandating critical infrastructure owners and operators to report a substantial cyber-attack and...more
3/22/2022
/ Critical Infrastructure Sectors ,
Cyber Attacks ,
Cybersecurity ,
FDIC ,
Federal Reserve ,
Homeland Security Cybersecurity & Infrastructure Security Agency (CISA) ,
OCC ,
Popular ,
Ransomware ,
Reporting Requirements ,
Ukraine
On January 26, 2022, the Consumer Financial Protection Bureau (CFPB) issued a request for public comment relating to “junk fees” consumers may be subjected to when engaging in financial services.
So what exactly is a...more
2/15/2022
/ Banking Sector ,
Comment Period ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Enforcement Actions ,
Fees ,
Financial Institutions ,
Financial Services Industry ,
Public Comment ,
Request For Information ,
Rulemaking Process
Nearly a year after issuing the notice of proposed rulemaking, the FDIC, OCC, and Federal Reserve have issued a final rule setting new notification requirements for banks and their third-party service providers in the event...more
The ways consumers make payments, including the data and technology associated with those payments, is becoming an increased focus of regulators. Financial institutions should carefully and thoroughly consider the recent...more
10/29/2021
/ Biden Administration ,
Compliance ,
Consumer Financial Protection Bureau (CFPB) ,
Cybersecurity ,
Data Management ,
Data Privacy ,
Dodd-Frank ,
EFTA ,
Executive Orders ,
Financial Services Industry ,
Gramm-Leach-Blilely Act ,
Payment Systems ,
Provider Payments ,
Regulatory Reform ,
Rulemaking Process
Over the past year and a half, the CFPB has been quietly taking steps toward implementing regulations around collecting data from commercial lenders regarding commercial loans. Those efforts culminated on September 1, 2021,...more
9/3/2021
/ Commercial Loans ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Data Collection ,
Dodd-Frank ,
Financial Services Industry ,
Lenders ,
Notice of Proposed Rulemaking (NOPR) ,
Proposed Rules ,
Section 1071 ,
Small Business
Does the federal Fair Debt Collection Practices Act (the FDCPA) apply to communications between a debt collector and its vendors? And, is the FDCPA a consumer privacy statute? In an apparent issue of first impression, the...more
5/7/2021
/ Consumer Privacy Rights ,
Debt Collection ,
Debt Collectors ,
Electronic Communications ,
FDCPA ,
Financial Services Industry ,
First Impression ,
Personal Information ,
Statutory Violations ,
Third-Party Service Provider ,
Vendors