Innovation

Subscribe to Innovation

On May 25, 2022, my colleagues, Mike Gordon, John Culhane and Ron Vaske published a blog which reported on a press release issued by the CFPB on the prior day entitled “CFPB Launches New Effort to Promote Competition and Innovation in Consumer Finance.”  The blog stated:

In its press release, the CFPB states that “[a]fter a review of these programs [the No Action Letter (NAL) and Compliance Assistance Sandbox (CAS) programs], the agency concludes that the initiatives proved to be ineffective and that some firms participating in these programs made public statements indicating that the Bureau had conferred benefits upon them that the Bureau expressly did not.”

… Continue Reading

The CFPB announced earlier this week that as part of a new approach to innovation in consumer finance, it is replacing its Office of Innovation and Operation Catalyst with a new office, the Office of Competition and Innovation, and eliminating its No Action Letter (NAL) and Compliance Assistance Sandbox (CAS) programs. … Continue Reading

AB-1864, which took effect on January 1, 2021 and significantly expanded the powers of the California Department of Financial Protection and Innovation, required the DFPI to establish a “Financial Technology Innovation Office.”

Adam Wright, Senior Counsel, recently joined the Department’s new Office of Financial Technology Innovation, having previously served as an enforcement attorney with the DFPI. … Continue Reading

Mr. Hunt shares his perspective on a range of issues, including how Rohit Chopra, CFPB Director-nominee, is likely to approach his new role, the CFPB’s likely approach to innovation and overdraft rulemaking under Mr. Chopra’s leadership, how banks are engaging with data aggregators, the OCC’s role and expectations for a new Comptroller, the status of Community Reinvestment Act rulemaking, and the potential for legislative changes.… Continue Reading

We are joined by Bret Ladine, the DFPI’s General Counsel.  We discuss the DFPI’s plans for adding new staff, promoting innovation through the new Financial Technology Innovation Office, providing guidance on CFPL exemptions, and handling complaints.  Other topics include the DFPI’s approach to its new authority regarding UDAAPs (which covers small business financing), registration of covered persons, and civil penalties.… Continue Reading

In this podcast, Paul Watkins, Director of the CFPB’s Office of Innovation, joins us to discuss the CFPB’s final trial disclosures, no-action letter, and FinTech sandbox policies.  Topics covered include the elements of each policy and the protection from liability available, the role of pre-application discussions between the CFPB and applicants, and the CFPB’s plans to engage in outreach to other federal and state regulators to maximize the value of approvals.… Continue Reading

Last week, the CFPB finalized its proposed revisions to its trial disclosures and no-action letter policies and also finalized its proposal to create a new FinTech sandbox policy.  It also announced the creation of the American Financial Innovation Network (ACFIN), a network of federal and state regulators to facilitate innovation, and issued its first no-action letter under the final revised policy.… Continue Reading

The CFPB has published a notice in the Federal Register seeking ideas on how it can use Tech Sprints to advance regulatory innovation and compliance.  Comments are due by November 8, 2019.

The CFPB’s notice describes Tech Sprints as a model that: 

“gather[s] regulators, technologists, financial institutions, and subject matter experts from key stakeholders for several days to work together to develop innovative solutions to clearly-identified challenges.… Continue Reading

The OCC’s Semiannual Risk Perspective report focuses on key issues that pose threats to bank safety and soundness and legal compliance.  Among such issues discussed in the Spring 2019 report, which generally reflects bank data as of December 31, 2018, are risks arising from financial innovation and new technologies.

One of the most significant issues discussed in the report involves artificial intelligence and alternative data, with the OCC highlighting the potential fair lending risks arising from these innovations. … Continue Reading

The CFPB has issued proposals to revise its disclosure sandbox and no action letter policy and create a product sandbox.  In this week’s podcast, we review what the CFPB has proposed, assess the criticism advanced by state attorneys general and consumer advocates, and discuss the CFPB’s likely next steps and how the proposals’ critics are apt to respond.… Continue Reading