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Deadline Approaching for Filing 2024 OFAC Annual Report of Blocked Property

The annual September 30 deadline for submitting the Annual Report of Blocked Property (ARBP) to the U.S. Department of Treasury Office of Foreign Assets Control (OFAC) is fast approaching. Under federal regulations, "all U.S....more

Proposed Visa/Mastercard Interchange Fee Settlement – A Sea Change or Drop in the Ocean for Merchants?

The series of antitrust class action lawsuits first brought by U.S. merchants against Visa and Mastercard in 2006 continued its winding path toward closure as the parties announced in March 2024 that they had reached a...more

CFPB Publishes 2023 Biennial CARD Act Report

On October 25, for the sixth time since its inception, the Consumer Financial Protection Bureau ("CFPB" or "Bureau") released its biennial report ("Report") evaluating the state of the consumer credit card market. The Credit...more

Quick Reactions to the CFPB's Potential Changes to Credit Reporting Practices

Takeaways from the CFPB's proposal, which addresses the Bureau's FCRA concerns – from brokers to data security to targeted marketing - The Consumer Financial Protection Bureau (CFPB) recently took its first step in making...more

Deadline Approaches for Filing OFAC Annual Report of Blocked Property

The annual Sept. 30 deadline for submitting the Annual Report of Blocked Property (ARBP) to the U.S. Department of Treasury Office of Foreign Assets Control (OFAC) is approaching once again. Under federal regulations, all...more

CFPB Officially Takes Aim at Credit Card Late Fees

The Consumer Financial Protection Bureau (CFPB or Bureau), under Director Chopra, is moving toward placing new restrictions on fees for the late payment of credit card debts. The proposed rulemaking represents a continuation...more

Credit Card Late Fees Scrutinized by CFPB

Financial institutions' longstanding practice of charging fees to consumers for the late payment of credit card debts is under scrutiny from the Consumer Financial Protection Bureau (CFPB) and its Director, Rohit Chopra....more

Readability and Deferred Interest Remain Concerns in CFPB's Biennial CARD ACT Report

On September 29, 2021, the Consumer Financial Protection Bureau (CFPB) released its fifth biennial report (Report) evaluating the state of the consumer credit card market. In addition to addressing impacts to the credit card...more

CFPB's Small Business Lending Data Collection Rulemaking

Last month, the Consumer Financial Protection Bureau (CFPB) issued a long-anticipated proposed rule (published in the Federal Register on October 8, 2021) requiring regulated financial institutions to collect and report small...more

Deadline Approaching for Filing OFAC Annual Report of Blocked Property

The annual September 30 deadline for submitting the Annual Report of Blocked Property (ARBP) to the U.S. Department of Treasury Office of Foreign Assets Control (OFAC) is approaching once again. Under federal regulations, all...more

A New Spring in the CFPB's Step

With a new administration incoming at the Consumer Financial Protection Bureau (CFPB) and the country turning the corner in its fight against the pandemic, the CFPB has begun to flex its regulatory muscles once again. From...more

Don't Say We Didn't Warn You – A Summary of California's Revamped Consumer Financial Protection Penalties

Though the January 1, 2021, effective date of the California Consumer Financial Protection Law (CCFPL) has now passed, financial institutions continue to work through the intricacies of the expansive new regulations. As we...more

CFPB Action Puts the Brakes on Auto Lender's Repossessions

As COVID-19 continues to impact personal finances in the United States, the Consumer Financial Protection Bureau (CFPB) has ramped up enforcement actions intended to safeguard a set of borrowers not protected by the CARES...more

Deadline Approaching for Filing Newly Expanded OFAC Annual Report of Blocked Property

The September 30 deadline is fast approaching for submitting the Annual Report of Blocked Property (ARBP) to the U.S. Department of Treasury Office of Foreign Assets Control (OFAC). ...more

CFPB Introduces New No-Action Letter Templates

On May 22, 2020, the Consumer Financial Protection Bureau (CFPB) introduced two new No-Action Letter (NAL) "templates," described as part of the Bureau's ongoing efforts to both spur the introduction of new personal finance...more

Reactions to CFPB's COVID-19 Response and Canada's Alternative Response

The U.S. government – through the CARES Act and the actions of myriad federal agencies including the Federal Reserve, FDIC, and CFPB – has acted to provide relief to credit card consumers affected by COVID-19. Credit card...more

Balancing Credit Reporting and Compassion In Light of COVID-19 (Updated)

Update March 31: The Coronavirus Aid, Relief, and Economic Security Act (CARES Act), which was signed into law on March 27, 2020, includes a section enacting an amendment to the Fair Credit Reporting Act (FCRA) requiring...more

Balancing Credit Reporting and Compassion In Light of COVID-19

While many financial institutions have taken steps to provide far-reaching financial relief to consumers impacted by the COVID-19 pandemic, not all consumers will get such relief. ...more

Governor Cuomo Orders COVID-19 Credit Relief

For the past few weeks, federal administrative, legislative, and regulatory bodies have been pushing financial institutions to offer far-reaching relief programs for consumers impacted by COVID-19 and governmental action...more

New York State Budget Proposal Would Expand Consumer Financial Protection Authorities

Governor Andrew Cuomo's 2020 agenda includes a series of consumer protection items designed to enhance the authority of the New York Department of Financial Services (NYDFS) to oversee broad swaths of licensed and unlicensed...more

Cashless Ban Update – New York City Legislation

Prior to 2019, just one state – Massachusetts – had legislation on its books mandating that retailers accept cash payments. Since February 2019, four major jurisdictions have passed such legislation....more

Open Banking, APIs, and Liability Issues

The concept of open banking has been around for much of the 21st century and has been instrumental in creating a host of new banking services. ...more

Deadline Approaching for Filing Newly Expanded OFAC Annual Report of Blocked Property

The September 30 deadline is fast approaching for submitting the Annual Report of Blocked Property (ARBP) to the U.S. Department of Treasury Office of Foreign Assets Control (OFAC). ...more

Recently Introduced Democratic Consumer Finance Proposals

With the Republican Party in control of the Senate and the White House, it is highly unlikely that financial regulations proposed by any Democrat will become law during the current administration....more

The Evolving Market for Purchase Installment Plans

Over the past couple of years, consumers have seen a proliferation of installment payment plans to finance the purchase of goods and services. At a high level, these plans are designed to help consumers pay off large...more

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