In an opinion authored by Chief Justice Roberts (the “DACA Opinion”), the Supreme Court has concluded that the rescission of the DACA program by the U.S. Department of Homeland Security (DHS) was arbitrary and capricious and hence in violation of the Administrative Procedure Act (APA). Several clients have asked whether the decision

On May 6, 2020, the CFPB issued an ECOA/Regulation B “Compliance Aid” containing three FAQs that clarify certain issues related to notification of action taken on Small Business Administration (“SBA”) Paycheck Protection Program (“PPP”) loan applications.  We understand that the Bureau provided the guidance in response to inquiries from banking trade associations on behalf of