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- 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
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On Nov. 9, 2022, the New York Department of Financial Services (NYDFS) issued a proposed second amendment to its 2017 cybersecurity regulation for financial service companies.[1] In July 2022…
Continue Reading NYDFS Proposes Significant Changes to Its Cybersecurity RegulationOn Sept. 29, 2022, the Financial Industry Regulatory Authority (FINRA) released Regulatory Notice 22-20, alerting members to changes to the Sanctions Guidelines (Guidelines), effective immediately. The notice discusses…
Continue Reading FINRA Releases Updated Guidelines and Sanctions for Securities Rule ViolationsOn July 14, 2022, the U.S. House of Representatives passed bipartisan legislation that, if passed by the Senate and signed into law, would expand the types of institutions required to…
Continue Reading ENABLERS Act Proposes to Expand Definition of ‘Financial Institution’; Impose BSA/AML Requirements on Professional Service ProvidersFederal regulatory agencies are closely monitoring crypto-asset developments and banking organizations’ participation in the crypto-asset industry. This GT Alert covers the guidance issued by the FDIC, CFPB, and the Federal…
Continue Reading Regulatory Scrutiny on the Rise of Bank and Crypto Company Dealings
On Aug. 11, 2022, the U.S. Consumer Financial Protection Bureau issued guidance indicating that financial institutions and service providers that fail to adopt sufficient data security measures to protect consumer…
Continue Reading CFPB Warns Insufficient Data Security Measures May Violate Consumer Financial Protection Act
On June 28, 2022, the Financial Crimes Enforcement Network (FinCEN) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a rare Joint Alert focused on the…
Continue Reading FinCEN and BIS Warn Financial Institutions About Potential Evasion of Russian and Belarusian Export Controls
On May 26, the Consumer Financial Protection Bureau (the Bureau or CFPB) issued its third Circular, emphasizing that creditors must adhere to the Equal Credit Opportunity Act (ECOA) and…
Continue Reading CFPB Circular 2022-03: Complex Lending Algorithms Cannot Excuse Failure to Provide Specific, Principal Reasons for an Adverse Credit Determination
On May 19, 2022, the Consumer Financial Protection Bureau (CFPB or Bureau) issued an interpretive rule (Section 1042 Interpretive Rule 5 19 2022) confirming that the Consumer Financial…
Continue Reading Deputizing State AGs: CFPB Issues Broad New Interpretive Rule on States’ Ability to Enforce Federal Consumer Protection Laws
On May 16, 2022, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a report regarding COVID-19 response metrics based upon its “observations from data obtained by 16 large mortgage…
Continue Reading CFPB Metrics Report Shows Increased Scrutiny of Borrower Access to Servicers, Information, and Loss Mitigation Opportunities