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

On July 31, 2020, the Office of the Comptroller of the Currency (OCC) approved the national bank charter application of Varo Bank, N.A., a wholly-owned subsidiary of fintech Varo Money, Inc. The approved application is for a full-service charter, not the OCC’s controversial FinTech charter that is currently the subject of ongoing litigation. In

As discussed in our June 12th post, the New York City Department of Consumer Affairs (“DCA”) issued new debt collection rules related to limited English proficiency servicing. These rules took effect June 27, 2020, but due to the COVID-19 crisis, DCA provided the industry with a 60-day enforcement grace period until August 26, 2020.

On August 3, 2020, the Federal Financial Institutions Examination Council (“FFIEC”) issued a joint statement to provide prudent risk management and consumer protection principles for financial institutions to consider when working with borrowers as consumer and business loans near the end of initial loan accommodation periods during the coronavirus pandemic. The guidance notes that the

Acting Comptroller Brooks recently revealed the OCC’s plans to create a national payments charter for payment processing companies.  After discussing the new charter’s intended purpose and benefits, we look at the OCC’s planned two-phase roll-out, how a payments charter would differ from the OCC’s fintech charter, other charter options for non-bank payment processors, and possible

As we reported, Acting Comptroller of the Currency Brian Brooks has previewed the OCC’s plans to introduce another special purpose national bank charter that would give payment companies a nationwide servicing platform and federal preemption of state laws regarding licensing and regulation of money transmitters and payment services providers.  Acting Comptroller Brooks’ statements drew

Last week, the FTC released two new reports about the agency’s findings from an April 2017 study of consumers’ experiences with the car buying process.  The FTC’s Bureau of Consumer Protection (BPC) authored a summary report called “Buckle Up: Navigating Auto Sales and Financing.”  The BPC, in partnership with the FTC’s Bureau of

Recently, the federal banking regulators issued four new sets of examination procedures. The OCC issued two significant examination booklets on sampling methodologies and UDAP/UDAAP, and the federal banking regulators, together with state financial regulators, issued interagency exam guidance for assessing safety and soundness of financial institutions in light of the ongoing impact of the COVID-19