On November 7, 2023, the Consumer Financial Protection Bureau (“CFPB”) proposed a rule that would allow the CFPB to supervise certain large nonbank companies that provide consumer financial services such as digital wallets...more
On April 10, 2018, the Federal Financial Institutions Examination Council (the “FFIEC”), an interagency body composed of the Board of Governors of the Federal Reserve System, Consumer Financial Protection Bureau, Federal...more
In a recent interview, Comptroller of the Currency Joseph Otting, announced the OCC’s plan to “clarify” its support of bank-offered deposit advance products. “Deposit advance products” are typically defined as small-dollar,...more
4/2/2018
/ Banking Sector ,
Banks ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Deposit Advances ,
Direct Deposit ,
Loans ,
OCC ,
Payday Lending Rule ,
Payday Loans ,
Rescission
On January 23, 2018, Mick Mulvaney, Acting Director of the Consumer Financial Protection Bureau (the “CFPB”), published an opinion editorial in The Wall Street Journal (the “Op-Ed”) describing his vision of the CFPB’s role in...more
2/21/2018
/ Adjudicatory Process ,
Call for Evidence ,
Civil Investigation Demand ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Protection Act ,
Cost-Benefit Analysis ,
Dodd-Frank ,
Enforcement Actions ,
Financial Institutions ,
Financial Services Industry ,
HMDA ,
Payday Lending Rule ,
Request For Information ,
Rulemaking Process ,
UDAAP ,
Wall Street Journal
On October 5, 2017, the Consumer Financial Protection Bureau (“CFPB”) released its nearly 1,700-page final rule for short-term loans (“Payday Lending Rule”). Notably, almost simultaneously with the CFPB’s announced Payday...more
On September 14, 2017, the Consumer Financial Protection Bureau (the “CFPB”) issued its first no-action letter (the “No-Action Letter”) concerning the operations of Upstart Network, Inc. (“Upstart”), a FinTech lender that...more
On July 10, 2017, the Consumer Financial Protection Bureau (the “CFPB”) finalized its proposed arbitration rule that will prohibit providers of certain consumer financial products and services from requiring a consumer to...more
7/13/2017
/ Arbitration ,
Banks ,
Class Action Arbitration Waivers ,
Congressional Review Act ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Dodd-Frank ,
FinTech ,
Mandatory Arbitration Clauses ,
Mortgage Lenders ,
OCC ,
Pre-Dispute Arbitration ,
Trump Administration