Stephanie Shea

Buchalter

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FDIC, FRB & OCC Issue Interagency Guidance on Third-Party Relationships: Risk Management

June 8, 2023 By: Stephanie Shea and Michael Flynn On June 6, 2023, the FDIC, FRB and OCC collectively issued a document entitled, “Interagency Guidance on Third-Party Relationships: Risk Management” (“2023 Guidance”). Prior...more

6/9/2023 / Enforcement , FDIC , FRB , New Guidance , OCC , Risk Management , Third-Party

Another Bank Settles Citizenship Discrimination Suit

The California Unruh Act (specifically, California Civil Code § 51) prohibits “all business establishments of every kind whatsoever” from discriminating based on citizenship or immigration status, among other things. That...more

6/1/2023 / Checking Accounts , Citizenship Status Discrimination , Class Action , Financial Services Industry , Savings Accounts , Settlement , Unruh Civil Rights Act

CFPB’s PACE Loan Proposal Could Impact Other Creditors

The Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018 amended TILA to require the CFPB to issue rulemaking addressing Property Assessed Clean Energy (PACE) loans. Specifically, the Act required the CFPB...more

5/30/2023 / Ability-to-Repay , Consumer Financial Protection Bureau (CFPB) , Creditors , HOEPA , Loans , PACE , Tax Assessment , Truth in Lending Act (TILA)

April was a Big Month for the LIBOR Transition: CFPB Revises Reg Z to Address 12-month LIBOR; Agencies Issue Joint Statement on...

May 1, 2023 By: Stephanie Shea As everyone knows, the remaining USD LIBOR tenors will expire on June 30, 2023. Also as everyone knows, the CFPB issued a final rule in December 2021, modifying Regulation Z to reflect the...more

5/2/2023 / Alternative Reference Rates Committee (ARRC) , Consumer Financial Protection Bureau (CFPB) , Final Rules , Libor , Regulation Z , Secured Overnight Funding Rate (SOFR)

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