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On June 23, 2022, the Office of the Comptroller of the Currency (OCC) released its Semiannual Risk Perspective (SRP) for spring 2022.  In the SRP, the OCC opines on its current safety and soundness concerns for banks under its regulatory umbrella, focusing on Russia sanctions, climate-related risk, and rising inflation.  Despite these challenges, the OCC believes that “[b]anks’ financial condition remains strong and positioned to deal with the economic headwinds.”… Continue Reading

Last week, the CFPB published a blog post with tips for consumers facing a cash flow emergency.

We were glad to see that the blog post included a warning to consumers about debt relief or settlement companies.  The CFPB advised consumers to beware of for-profit debt relief or settlement companies that promise to pay off consumers’ debts for “pennies on the dollar” or charge fees before settling debts, guarantee to eliminate unsecured debt, or tell consumers to stop communicating with creditors.… Continue Reading

The CFPB’s June 2017 complaint report could serve as a call to arms to state attorneys general and regulators.  Unlike the CFPB’s prior monthly complaint  reports, the June 2017 report does not highlight complaints about one product  or complaints from consumers from one state.  Instead, the new report, which the CFPB calls a “special edition,” provides expanded data and analysis on a state-by-state basis of all complaints received by the CFPB as of April 1, 2017.  … Continue Reading

On May 26, the House of Representatives Committee on Rules announced that House members have until June 2 to propose amendments to the Financial Choice Act bill.  The Chairman of the House Financial Services Committee, Jeb Hensarling, is expected to introduce an amendment to strike from the bill the provision which purports to repeal the Durbin Amendment. … Continue Reading

Tom Dresslar, the Deputy Commissioner for Policy and Planning at the California Department of Business Oversight, California’s state bank regulator, has retired.  Mr. Dresslar joined the DBO in late 2014 after a long career in California state government and, before that, as the Sacramento Bureau Chief for the Daily Journal, Los Angeles’s daily legal newspaper. … Continue Reading

The CFPB’s Office of Servicemember Affairs (OSA) has issued its fifth annual report to Congress addressing issues raised and complaints submitted by servicemembers, veterans, and their families.

This year, however, the Bureau took a novel approach by presenting the report “within the construct of the ‘military lifecycle’” in an attempt to “consider issues and complaints in the very context in which they arise.”… Continue Reading

Adding to the growing body of cases disputing the CFPB’s authority to issue civil investigative demands (“CID”), a U.S. district court judge in the Central District of California, on May 17, rejected multiple challenges and ordered a company to comply with a CID within fifteen days of the decision. The defendant, Future Income Payments, previously attempted a John Doe challenge to the CID in the U.S.… Continue Reading

Last Thursday, by a party-line vote of 34-26, the House Financial Services Committee approved the Financial CHOICE Act (H.R. 10) proposed by Committee Chairman Jeb Hensarling.

In addition to overhauling the CFPB’s structure and authority, the bill would make significant changes to the rulemaking process followed by the CFPB and other financial services regulators, including the Fed, FDIC, OCC and NCUA. … Continue Reading

The Administrator of the Uniform Consumer Credit Code for the State of Colorado, Julie Ann Meade, has filed motions to dismiss the complaints filed in federal court by two state-chartered banks seeking to permanently enjoin enforcement actions brought by the Administrator against the banks’ nonbank partners.  According to the complaints, these nonbank partners market and service loans originated by the banks, and the banks sometimes sell these loans to their partners.… Continue Reading