CFPB, Federal Agencies, State Agencies, and Attorneys General
The CFPB has issued a policy statement concerning COVID-19 considerations that will be relevant to how the CFPB chooses to exercise its supervisory and enforcement authority regarding compliance with the Fair Credit Reporting Act and Regulation V, especially in light of the CARES Act.
The CFPB states that it “understands that the current crisis impacts…
In our examination of two recent OCC BSA/AML consent orders, one with a bank and another with an individual in-house professional, we review the OCC’s allegations underlying the orders and how the OCC focuses on the core pillars of BSA/AML compliance when choosing to pursue enforcement. We also discuss the takeaways for boards and management…
Pennsylvania’s Attorney General Josh Shapiro announced this week that his office has launched “PA CARE Package,” a consumer relief program for PA consumers impacted by the COVID-19 pandemic.
The program is intended to implement and expand on the consumer protections provided by the federal CARES Act. The press release issued by the PA AG’s Office…
The CFPB has published a request for information (RFI) in today’s Federal Register seeking comments and information to assist its Taskforce on Federal Consumer Financial Law. Comments on the RFI must be received by June 1, 2020.
The CFPB created the Taskforce in October 2019 to examine ways to harmonize and modernize federal consumer financial…
On March 26, the CFPB issued three policy statements designed to provide flexibility to banks and financial services companies to allow them to focus on responding to customers in need during the COVID-19 pandemic.
First, in two separate policy statements, the CFPB announced that it is postponing certain industry data collection deadlines. Specifically, the Bureau…
We have been closely following a lawsuit challenging a 2019 Nevada amendment that relates to the treatment of spousal credit history during the credit application process. Senate Bill 311, which went into effect on October 1, 2019, allows an applicant for credit with no credit history to request that the creditor treat the applicant’s credit…
How will regulatory agencies like the CFPB, FTC, and State Attorneys General react to the consumer financial impacts of COVD-19? What kinds of consumer litigation may be spurred by the crisis?
On Monday, April 6, 2020, from 12:00 p.m. to 1:00 p.m. ET, Ballard Spahr will hold a webinar, “Consumer Financial Regulatory and Litigation Fallout…
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) includes the following key provisions that affect financial institutions and regulation of financial institutions:
Section 4003 – Emergency Relief and Taxpayer Provisions
Section 4003 of the CARES Act generally authorizes the Treasury Secretary to make loans, loan guarantees, and other investments in support of eligible…
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) includes the following provisions of particular interest to members of the consumer financial services industry:
Credit Reporting. Section 4021 (Credit Protection During COVID-2019) amends the Fair Credit Reporting Act to impose new COVID-19 related reporting requirements on furnishers of information to consumer reporting agencies. Under…
On March 27, 2020, the Massachusetts Attorney General filed an emergency regulation interpreting the Massachusetts Consumer Protection Act, M.G.L. Chapter 93A, to address certain practices by creditors and debt collectors that it has determined to be unfair and deceptive under present circumstances. The regulation, entitled “Unfair and Deceptive Debt Collection Practices During the State…
