Go-To Guide:
- CFPB proposes rule requiring nonbanks to “register” with the CFPB if they include certain terms and conditions in their form contracts, including in their website terms of use
News & Commentary on Financial Regulatory and Compliance Matters
Gil Rudolph focuses his practice on the representation of finance companies, banks, mortgage originators and servicers, lease company transactions, retail installment transaction financers and other consumer financial service providers in regulatory and litigation matters. Gil also represents various alternative financial service providers, including small dollar/short term lenders, check cashers, pawn and auto title lenders. He additionally represents various participants in the credit, debit, and prepaid card issuance and processing industries.
Go-To Guide:
The Consumer Financial Protection Bureau (CFPB or the Bureau) announced it would begin issuing Consumer Financial Protection Circulars (Circulars) to a “broad set of government agencies responsible for enforcing federal…
Continue Reading CFPB to Issue Consumer Financial Protection Circulars to Increase Transparency and Align Enforcement
As nonbanks comprise an ever-greater share of the consumer-finance market, on April 25, 2022, the Consumer Financial Protection Bureau (CFPB, or the Bureau) announced it would invoke its “unused” legal…
Continue Reading CFPB to Examine Nonbank Financial Companies – Including Fintechs – that Pose Risk to Consumers
The Consumer Financial Protection Bureau has expanded its anti-discrimination oversight and enforcement of covered persons to all consumer finance products and services, regardless of whether they involve an extension of…
Continue Reading CFPB Expands Anti-Discrimination by Applying UDAAP to Credit and Non-credit Products
On Jan. 20, 2022, the Board of Governors of the Federal Reserve System (Fed) issued the Money and Payments: The U.S. Dollar in the Age of Digital Transformation paper (Paper)…
Continue Reading Federal Reserve System Takes First Step Toward Creating Its Own Digital Currency
On June 25, 2020, the Federal Deposit Insurance Corporation (FDIC) issued a final rule that attempts to resolve the legal uncertainty created by the 2015 holding of the U.S. Court…
Continue Reading FDIC Follows OCC Lead in Attempt to Clarify Madden Uncertainty
On May 20, 2020, the Office of the Comptroller of the Currency (OCC), which regulates national banks, released a Final Rule intended to strengthen and modernize the implementation of the
With the announcement of Richard Cordray’s resignation as Director of the federal Consumer Financial Protection Bureau (CFPB) by the end of November 2017, the latest D.C. guessing game is who…
Continue Reading Richard Cordray Resigns — Who’s going to mind the CFPB store?
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 …
Continue Reading U.S. Court of Appeals for D.C. Circuit Vacates Panel Decision in PHH v. CFPB, Grants Rehearing En Banc
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…
Continue Reading OCC Consideration of Special Purpose Fintech Charters Draws Rapid Reaction for State Banking Regulators