Gil Rudolph

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U.S. Court of Appeals for D.C. Circuit Vacates Panel Decision in PHH v. CFPB, Grants Rehearing En Banc

On Feb. 16, 2017, the U.S. Court of Appeals for the D.C. Circuit granted the request for en banc review by the Consumer Financial Protection Bureau (CFPB) in the PHH v. CFPB matter.[1]  The order vacates the prior judgment by a three-judge panel that the CFPB’s structure was constitutionally infirm, and which remedied that infirmity … Continue Reading

OCC Consideration of Special Purpose Fintech Charters Draws Rapid Reaction for State Banking Regulators

On Dec. 2, 2016, the Office of the Comptroller of the Currency (OCC) published a preliminary proposal to create a national bank charter for financial technology companies (fintech). The OCC’s rationale in support of the proposal was that such a charter could promote the safety and soundness of fintech institutions, bring greater legal and regulatory … Continue Reading

Brett Kitt Spoke at the ABA Consumer Financial Services Committee Meeting

Greenberg Traurig’s Brett Kitt, Of Counsel in the Financial Regulatory and Compliance Practice, participated in the American Bar Association Consumer Financial Services Committee Meeting, Sept. 17-19, 2015, in Chicago, IL. Kitt was a panelist in the session titled “The CFPB Complaint Database.”  The discussion addressed the Consumer Financial Protection Bureau’s  (CFPB) process for addressing consumer … Continue Reading

CFPB Observer: Recent Developments from July 7-10, 2015

CFPB Issues Report on Servicers Servicing Servicemembers’ Student Loans On July 7, the CFPB released a report covering student loan servicing complaints received by the CFPB from servicemembers. The report, “Overseas & Underserved: Student Loan Servicing and the Cost to Our Men and Women in Uniform,” summarizes issues the CFPB has observed with respect to … Continue Reading

Fred E. Karlinsky Presented at the Association of Insurance Compliance Professionals Gulf States Chapter’s 2015 Education Day

Fred E. Karlinsky, co-chair of Greenberg Traurig’s Insurance Regulatory & Transactions Practice, presented at the June 26 program at the Association of Insurance Compliance Professionals (AICP) Gulf States Chapter’s 2015 Education Day in Atlanta. The program featured a variety of speakers focusing on insurance industry compliance related topics. Karlinsky, a frequent speaker on insurance-related trends … Continue Reading

CFPB Observer: Recent Developments from June 2015

CFPB Releases Spring 2015 Rulemaking Agenda The CFPB recently released its spring 2015 rulemaking agenda as required by the Regulatory Flexibility Act. It described the following upcoming rulemakings: Home Mortgage Disclosure Act. The CFPB issued a proposed rule in August 2014 to implement Dodd-Frank Act amendments to the Home Mortgage Disclosure Act (HMDA). The proposal … Continue Reading

CFPB Observer: Recent Developments from April 27 – May 1, 2015

The authors discuss current developments with the Consumer Financial Protection Bureau (CFPB) including a report of consumer complaints issued by the CFPB’s Office of Servicemember Affairs; an enforcement action against a bank for overdraft practices; an enforcement action against a title company and its mortgage loan officers; the Annual Fair Lending Report issued by CFPB’s … Continue Reading

CFPB Observer: Recent Developments from April 13-17, 2015

The authors discuss current developments with the Consumer Financial Protection Bureau (CFPB) including an enforcement action against a tax-refund anticipation loan company and its owners; guidance regarding housing counselor information; a final rule on the credit card agreement submission process; and an upcoming research conference. Continue Reading.… Continue Reading

CFPB Observer: Recent Developments from April 2-10, 2015

The authors discuss current developments with the Consumer Financial Protection Bureau (CFPB) including an enforcement action against a collection agency and its service providers, an action against a mortgage lender for deceptive advertising, an update to the Supervision and Examination Manual, and meeting notices for the CFPB’s Community Bank Advisory Council and the CFPB’s Academic … Continue Reading

CFPB Outlines Payday Loan Rule

The CFPB recently announced the details of the payday loan rule that it is considering proposing. While it nominally targets traditional short-term, small-dollar lending that is commonly referred to as “payday lending,” the scope of the rule under consideration would more broadly cover vehicle title loans, deposit advance products, and certain high-cost installment and open-end … Continue Reading

CFPB Observer: Recent Developments from Feb. 16-27, 2015

The authors discuss current developments with the Consumer Financial Protection Bureau (CFPB) including a consumer focus group study on credit reports, a proposed rule that would improve the consumer credit card agreement disclosure process, an upcoming field hearing on consumer arbitration agreements, and an upcoming Credit Union Advisory Council meeting. Continue Reading.… Continue Reading

CFPB Observer: Recent Developments from Feb. 9-13, 2015

The authors discuss current developments with the Consumer Financial Protection Bureau (CFPB) including an issued report and consumer advisory on reverse mortgages, an enforcement action against a non-bank mortgage lender for alleged deceptive advertising practices and kickbacks, and separate enforcement actions and a civil suit against several mortgage lenders for misleading advertising practices. Continue Reading.… Continue Reading

CFPB Observer: Recent Developments from Jan. 26-30, 2015

The authors discuss current developments with the Consumer Financial Protection Bureau (CFPB) including a proposed rule amending mortgage rules relating to small creditors, a Compliance Bulletin providing guidance on the CFPB’s regulations governing the use and disclosure of confidential supervisory information, and guidance on private student loans with graduated repayment terms. Continue Reading.… Continue Reading

CFPB Observer: Recent Developments from Dec. 15, 2014 – Jan. 2, 2015

The authors discuss current developments with the Consumer Financial Protection Bureau (CFPB) including a report on college credit card agreements, a lawsuit against a national wireless carrier for third-party charges, an action against a retailer for unlawful debt collection practices, and an extension of the foreclosure protection period for servicemembers. Continue Reading.… Continue Reading
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