On August 11, the Federal Financial Institutions Examinations Council (FFIEC) issued new guidance, providing examples of effective authentication and access risk management principles and practices for financial institutions....more
The U.S. District Court for the Northern District of California recently issued an order setting September 30 as the deadline for the CFPB to issue a notice of proposed rulemaking (NPRM) on small business lending data based...more
The CFPB recently announced that its two final debt collection rules implementing the Fair Debt Collection Practices Act (FDCPA) will take effect as planned on November 30. The CFPB had previously proposed extending the final...more
On July 12, the CFPB issued a consent order against a FinTech company for facilitating point of sale financing activities without authorization from consumers. The consent order requires the company to pay up to...more
On July 13, the Federal Reserve, FDIC, and OCC proposed risk management guidance to help banking organizations manage risks related to third-party relationships, including relationships with vendors, FinTech companies,...more
7/20/2021
/ Banking Sector ,
Comment Period ,
Consumer Financial Protection Bureau (CFPB) ,
Contract Negotiations ,
Due Diligence ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Government Agencies ,
OCC ,
Proposed Guidance ,
Regulatory Oversight ,
Risk Management ,
Third-Party Relationships ,
Third-Party Service Provider
On July 6, the CFPB posted a blog titled, “Should you buy now and pay later?” describing how buy now pay later (BNPL) deferred payment options work, and the benefits and risks that come with BNPL. Generally, if a consumer...more
On June 29, the CFPB released its summer 2021 Supervisory Highlights. The findings of the report, which cover examinations that generally were completed between January 1, 2020 to December 31, 2020, are issued to “help...more
On June 15, the Senate swore in President Biden nominee Lina Khan as Chair of the FTC following confirmation by vote of 69-28. Her current term on the Commission will expire on September 25, 2024. Khan noted that she looks...more
On June 16, the CFPB issued an interpretive rule reversing its prior determination that it lacked authority to examine institutions for compliance with the Military Lending Act (MLA). In 2018, the CFPB discontinued checking...more
The CFPB recently released new FAQs regarding the Mortgage Servicing Rule and Regulation X and Regulation Z relating to escrow account guidance and analysis.
Putting it Into Practice: Some key takeaways include the...more
On June 4, the CFPB issued eight updated FAQs to the unauthorized transfer and error resolution provisions under the Electronic Fund Transfer Act (EFTA) and Regulation E. Highlights from the FAQs include the following:...more