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Special Alert: Federal court says state bank, fintech partner must face Maryland’s allegation of unlicensed lending before state ALJ
A federal court late last month told a state-chartered bank and its fintech partner that they must return to a state administrative law proceeding to fight a Maryland enforcement action alleging that their failure to obtain a license to lend and collect on loans violated state law — potentially...
Special AlertsSpecial Alert: CFPB revises UDAAP manual to include discriminatory practices
On March 16, the Consumer Financial Protection Bureau announced significant revisions to its Unfair, Deceptive, or Abusive Acts or Practices exam manual , in particular highlighting the CFPB’s view that its broad authority under UDAAP allows it to address discriminatory conduct in the offering of...
Special AlertsSpecial Alert: Latest developments in OFAC sanctions against Russia
Beginning February 21, the U.S. Department of the Treasury’s Office of Foreign Assets Control has issued significant sanctions in response to the Russian Federation’s military invasion of Ukraine and its recognition of Ukraine’s separatist regions. Since Buckley’s last update on February 25 , there...
Special AlertsSpecial Alert: NYDFS guidance on cybersecurity and virtual currency responds to events in Ukraine
The New York Department of Financial Services last week issued guidance on its cybersecurity and virtual currency regulations in response to the Russian military actions in Ukraine and recently imposed sanctions. NYDFS specifically raised the specter of elevated cyber risk due to ongoing...
Special AlertsSpecial Alert: Russian invasion of Ukraine triggers significant sanctions (updated)
Over the past few days, and following weeks of clear signals that sanctions would be imposed in response to military activity, the Biden administration issued significant new sanctions in response to the Russian Federation’s military invasion of Ukraine and its recognition of Ukraine’s separatist...
Special AlertsSpecial Alert: Russian invasion of Ukraine triggers significant sanctions
On February 21 and 22, following weeks of clear signals that sanctions would be imposed in response to military activity, the Biden administration issued significant new sanctions in response to the Russian Federation’s recognition of separatist regions of Ukraine and incursions of Russian troops...
Special AlertsSpecial Alert: CFPB proposes small business loan data collection regime
Over a decade ago, Congress enacted an amendment to the Equal Credit Opportunity Act that directed the Consumer Financial Protection Bureau to implement a new regime for small business loan data collection similar to the regime that exists in the mortgage industry. Last week, a month before a court...
Special AlertsSpecial Alert: Colorado enacts comprehensive consumer privacy law
On July 7, the Colorado governor signed SB 21-190 to create the Colorado Privacy Act (CPA) and establish a framework for personal data privacy rights. Colorado now joins Virginia and California as the third state in the nation to enact comprehensive consumer privacy laws. In 2018, California became...
Special AlertsSpecial Alert: CFPB specifies pandemic foreclosure protections and signals tight supervision and enforcement around servicer efforts
The Consumer Financial Protection Bureau’s Covid-relief mortgage servicing rule issued yesterday steered away from a nationwide foreclosure freeze as initially proposed, instead creating heightened protections for those borrowers who became seriously delinquent during the pandemic. The distinction...
Special AlertsSpecial Alert: CFPB proposes to halt foreclosure starts from August 31 until 2022 and create new loss mitigation requirements for servicers
The Consumer Financial Protection Bureau on April 5 issued a proposal that would broadly halt foreclosure initiations on principal residences from August 31, 2021 until 2022, and change servicing rules to promote consumer awareness and processing of Covid-relief loss mitigation options. Although...
Special Alerts