Taylor R. Gess

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CFPB Issues Remittance Transfer Consent Order

By Taylor R. Gess on December 23, 2020

Posted in CFPB Enforcement, Regulatory and Enforcement, Remittance Transfers

On December 21, 2020, the CFPB issued its third consent order involving violations of Subpart B of Regulation E, 12 C.F.R. §§ 1005.30 to 1005.36, the Remittance Transfer Rule (“Remittance Rule”) in the last four months and fourth order since August 2019. This most recent consent order was issued against Envios de Valores La Nacional Corp.… Continue Reading

CFPB issues template for employee savings program under compliance assistance sandbox policy

By Taylor R. Gess on August 10, 2020

Posted in CFPB, Deposit Accounts, Regulatory and Enforcement

The CFPB recently announced that it has issued a Compliance Assistance Statement of Terms Template (“CAST Template”) through its Compliance Assistance Sandbox Policy (“CAS Policy”) after receiving an application from Build Commonwealth, Inc. (“Commonwealth”).

The Commonwealth CAST Template can be used by employers as the basis for an application to the CFPB to obtain approval for an automatic savings program to assist employees in building emergency savings (“Autosave Program”). … Continue Reading

NYDFS Student Lending Initiative

By Taylor R. Gess on September 11, 2019

Posted in Regulatory and Enforcement, State regulation, Student Loans

New York Department of Financial Services (NYDFS) Superintendent, Linda A. Lacewell, recently wrote an Opinion Article in the New York Daily News, addressing the student lending industry. According to Lacewell, the Trump administration and Education Secretary Betsy DeVos have “dismantled critical consumer protections available to students” and “gutt[ed]” the Consumer Financial Protection Bureau’s student lending office.… Continue Reading