While we reported in our last Cabinet News & Views on the final rule regarding quality control standards for AVMs which will take effect one year after publication in the Federal Register (i.e., it has not yet been...more
As February already begins to wind down and all of us are wondering what we might have missed so far this year, here is a round-up of additional regulatory activities in financial services...more
2/23/2024
/ Bank Merger Act ,
Banks ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Debit and Credit Card Transactions ,
ECOA ,
FDIC ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Services Industry ,
New Guidance ,
NRSRO ,
OCC ,
Securities and Exchange Commission (SEC) ,
Supervisory Highlights
On September 20th, the Consumer Financial Protection Bureau (“CFPB”) published guidance – Consumer Financial Protection Circular, 2023-03 – regarding the list of reasons that must be provided when an applicant is denied...more
9/21/2023
/ Adverse Action ,
Artificial Intelligence ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Discriminatory Lending Practices ,
ECOA ,
Fair Lending ,
Financial Regulatory Reform ,
Financial Services Industry ,
Machine Learning ,
New Guidance ,
Regulation B
The Office of the Comptroller of the Currency (“OCC”) and the Federal Deposit Insurance Corporation (“FDIC”) (collectively, the “Agencies”) provided supervisory guidance this week on certain overdraft practices. Of particular...more
4/28/2023
/ Consumer Financial Protection Bureau (CFPB) ,
FDIC ,
Federal Reserve ,
Financial Services Industry ,
FRB ,
New Guidance ,
OCC ,
Overdraft Rule ,
UDAAP ,
UDAP ,
Unfair or Deceptive Trade Practices
The Consumer Financial Protection Bureau (“CFPB”) issued guidance on February 7 in the form of an Advisory Opinion intended to “protect mortgage borrowers from pay-to-play digital comparison-shopping platforms.” Specifically,...more
In many corners of financial services, Environmental, Social and Governance (“ESG”) concerns are driving innovation, SEC disclosure requirements, and even risk and compliance assessments. However, first among the prudential...more
On July 15, the Federal Deposit Insurance Corporation (“FDIC”) issued an updated Q&A regarding how companies involved in managing deposits can determine whether such deposits should be considered brokered, and/or whether they...more
The Consumer Financial Protection Bureau (“CFPB”) released a regulatory Circular providing guidance regarding the use of “complex algorithms” to assess whether a consumer should be extended credit. Often referred to as “black...more
6/3/2022
/ Algorithms ,
Artificial Intelligence ,
Black Box ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Credit ,
Credit Applicants ,
Credit Discrimination ,
ECOA ,
Financial Services Industry ,
New Guidance
The FDIC released a “Small Entity Compliance Guide” that provides a summary of its final rule allowing for the “simplification of deposit insurance,” which takes effect on April 1, 2024....more
The Consumer Financial Protection Bureau (CFPB) issued an advisory opinion on May 9, confirming that for purposes of the Equal Credit Opportunity Act (“ECOA”) and its implementing regulation, Regulation B, the intended...more