News & Analysis as of

Financial Regulatory Reform Preemption Regulatory Agenda

Cadwalader, Wickersham & Taft LLP

Chevron Isn't Slowing CFPB Down, As They Issue a New Proposed Rule on Mortgage Servicing

On July 24th, the Consumer Financial Protection Bureau (CFPB) issued a new proposed rule “Streamlining Mortgage Servicing for Borrowers Experiencing Payment Difficulties”, with a comment period ending on September 9, 2024....more

Skadden, Arps, Slate, Meagher & Flom LLP

Supreme Court Clarifies Standard for Analyzing National Bank Act Preemption

In Cantero v. Bank of America, the U.S. Supreme Court clarified the standard for analyzing whether the National Bank Act (the NBA) preempts state laws regulating banks chartered under the NBA. In doing so, the Court rejected...more

Ballard Spahr LLP

“True Lender Act” Bill Proposed in Maryland

Ballard Spahr LLP on

Maryland has joined the ranks of states considering legislation that would codify elements of “true lender” theory in an effort to impose federally preempted state licensing requirements and rate caps on loans to Maryland...more

Ballard Spahr LLP

Republican lawmakers urge OCC to address Madden through rulemaking

Ballard Spahr LLP on

The Republican members of the House Financial Services Committee have sent a letter to Comptroller of the Currency Joseph Otting urging the OCC to make action to address the uncertainty created by Second Circuit’s Madden...more

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