News & Analysis as of

Advisory Opinions Financial Institutions

Nutter McClennen & Fish LLP

Nutter Bank Report: August 2024

CFPB Issues Filing Instructions Guide for Small Business Lending Data - The CFPB has published instructions for banks and other covered financial institutions to submit small business lending data that is required to be...more

Bradley Arant Boult Cummings LLP

Banks and Credit Unions Utilizing Ineffective Chatbots May Risk Violating Federal Law

In an October 2023 advisory opinion, the Consumer Financial Protection Bureau (CFPB) put large banks and credit unions on notice that the use of chatbots and other technologies could increase the risk of violating federal law...more

Ballard Spahr LLP

Consumer Finance Monitor Podcast Episode: Navigating the Consumer Financial Protection Bureau’s Proposed Personal Financial Data...

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In October 2023, the CFPB issued a groundbreaking proposal on personal financial data. This episode, which repurposes a webinar, begins with a review of the background of the rulemaking. We then discuss key provisions of the...more

Bradley Arant Boult Cummings LLP

CFPB Issues Advisory Opinion Restricting Fees Charged for Consumer’s Requests for Account Information

In October 2023, the CFPB issued an advisory opinion titled, “Consumer Information Requests to Large Banks and Credit Unions.” The upshot of the advisory opinion is that covered financial institutions responding to consumer...more

Cadwalader, Wickersham & Taft LLP

CFPB Announces Large Banks and Credit Unions May Not Charge for Account Information

The Consumer Financial Protection Bureau ("CFPB") announced last week the publication of an Advisory Opinion regarding “Consumer Information Requests to Large Banks and Credit Unions.” The Advisory Opinion applies to “large...more

Troutman Pepper

CFPB Advises Large Banks on Compliance with CFPA § 1034(c)

Troutman Pepper on

On October 11, the Consumer Financial Protection Bureau (CFPB or Bureau) issued an advisory opinion regarding § 1034(c) of the Consumer Financial Protection Act (CFPA), which requires large banks and credit unions to comply...more

Ballard Spahr LLP

CFPB issues advisory opinion on fees charged by large banks and credit unions to respond to information requests and releases data...

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As we have previously reported on this blog and discussed on our Consumer Finance Monitor Podcast, last year, the CFPB embarked on a campaign orchestrated by the Biden Administration to eliminate “junk fees.” ...more

Adams and Reese LLP

Consumer Financial Protection Bureau Issues “Zombie Mortgage” Advisory Opinion

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The Consumer Financial Protection Bureau (CFPB) issued an advisory opinion last month to affirm that the Fair Debt Collection Practices Act (FDCPA) and its implementing Regulation F prohibit a debt collector, as that term is...more

King & Spalding

OIG Issues Favorable Advisory Opinion Involving an Arrangement With 0% Financing Options for a DME Manufacturer’s Customers

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On June 17, 2022, OIG issued a favorable advisory opinion allowing involving an arrangement in which a durable medical equipment (DME) manufacturer makes zero-interest financing available to its customers. The advisory...more

Harris Beach PLLC

OIG Decides Not to Impose Sanctions on Medical-Equipment Manufacturer in Financial Arrangement

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Department of Health and Human Services Office of Inspector General (“OIG”) Advisory Opinion 22-13 Issued: June 23, 2022 This opinion addresses a durable medical equipment (“DME”) manufacturer’s arrangements with...more

Bass, Berry & Sims PLC

OIG Approves DME Manufacturer Loan Program in Latest Advisory Opinion

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On June 23, the Office of Inspector General (OIG) for the U.S. Department of Health and Human Services published Advisory Opinion 22-13, approving an arrangement under which a durable medical equipment (DME) manufacturer...more

Goodwin

Agencies Issue Joint Proposal to Strengthen and Modernize CRA Regulations

Goodwin on

Regulatory Developments - Agencies Issue Joint Proposal to Strengthen and Modernize CRA Regs - On May 5, the FDIC, the FRB and the OCC issued a joint Notice of Proposed Rulemaking (NPR) to “strengthen and modernize” the...more

Goodwin

SEC Finalizes Reforms Under Investment Advisers Act

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In this Issue. The Securities and Exchange Commission (SEC) finalized reforms under the Investment Advisers Act to modernize rules that govern investment adviser advertisements and payments to solicitors, and published a risk...more

Goodwin

Financial Services Weekly Roundup: Code Libor – SEC And OCIE Issue Risk Alert In Preparation Of Libor Discontinuation

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In This Issue. The Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert about the scope and content of examinations OCIE plans to conduct of various...more

Ballard Spahr LLP

FinCEN Issues Advisory on Foreign Jurisdictions with AML Deficiencies

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On November 12, 2019, FinCEN issued its latest Advisory on the Financial Action Task Force-Identified Jurisdictions with Anti-Money Laundering and Combatting the Financing of Terrorism Deficiencies and Relevant Actions by the...more

Akin Gump Strauss Hauer & Feld LLP

FinCEN Releases Advisory for Banks, MSBs on Potentially Illicit Transactions with Iran

• On October 11, 2018, FinCEN released an advisory to help U.S. financial institutions better detect potentially illicit transactions related to Iran. • The advisory describes how Iran attempts to access the international...more

Stinson - Corporate & Securities Law Blog

FINRA Relaxes Rules for M&A and Private Placement Brokers

The SEC has approved a series of FINRA rules that are meant to simplify regulation of firms engaged as M&A brokers and those who conduct other limited activities. While the rules may be simpler, it still looks like a...more

Holland & Knight LLP

FinCEN's Busy August Yields Noteworthy Anti-Money Laundering Developments

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August was a busy month for the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN). Among other initiatives, FinCEN issued its long-awaited proposed regulations on customer due diligence (CDD)...more

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