Amanda Mollo

Firm/Organization: Morrison & Foerster LLP

Blogs: MoFo ReEnforcement: The Enforcement Blog

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MoFo ReEnforcement: The Enforcement Blog

CFPB Issues RFI on Guidance and Implementation Support

By Obrea Poindexter, Jeremy Mandell & Amanda Mollo

March 30, 2018

On March 29, 2018, the CFPB issued a Request for Information on the CFPB’s guidance and implementation support. The RFI is the tenth in a series that solicits public feedback on the Bureau’s operations and the regulations for which it is responsible. A press release accompanying the RFI states that the Bureau will be “assessing the overall effectiveness and accessibility of its guidance materials and activities” and “considering whether it would be appropriate to make…

MoFo ReEnforcement: The Enforcement Blog

CFPB Issues RFI on Inherited Regulations

By Obrea Poindexter, Jeremy Mandell & Amanda Mollo

March 26, 2018

On March 26, 2018, the CFPB published a Request for Information on the CFPB’s inherited regulations and inherited rulemaking authorities. The RFI is the ninth in a series that solicits public feedback on the Bureau’s operations, and the regulations for which it is responsible. Comments on the RFI regarding inherited regulations are due by June 24, 2018. Read our client alert.…

MoFo ReEnforcement: The Enforcement Blog

CFPB Requests Feedback on Rulemaking Process

By Obrea Poindexter, Crystal Kaldjob & Amanda Mollo

March 8, 2018

On March 7, 2018, the CFPB released a Request for Information regarding the Bureau’s rulemaking process, the seventh RFI in its initiative to reexamine the Bureau’s existing policies and procedures under Acting Director Mick Mulvaney’s leadership. Through this latest RFI, the Bureau seeks feedback “on all discretionary aspects of the Bureau’s [rulemaking] processes, including current practices, timelines, and potential improvements in each stage of these processes.” Read our client alert.…

MoFo ReEnforcement: The Enforcement Blog

SEC Breaks Silence on Certain Cryptocurrency Exchanges

By Susan Gault-Brown & Amanda Mollo

March 8, 2018

On March 7, 2018, the staff of the Divisions of Enforcement and Trading and Markets of the SEC issued a public statement regarding exchanges and other secondary trading platforms that list and/or facilitate the trading of coins and tokens online. The statement emphasizes that platforms offering the trading of digital assets that are securities, including many (if not all) coins and tokens issued through initial coin offerings (ICOs), must register with the SEC as a…

MoFo ReEnforcement: The Enforcement Blog

With CID Request, CFPB Follows Through on Plan to Review Functions

By Don Lampe, Steven Kaufmann & Amanda Mollo

February 1, 2018

On January 26, 2018, the CFPB published a Request for Information in the Federal Register regarding the Bureau’s Civil Investigative Demand processes. According to the Bureau’s related press release, the RFI is the first part of Acting Director Mick Mulvaney’s “call for evidence” about the Bureau’s functions. As presaged in the Bureau’s press release, the RFI is designed to “ensure the Bureau is fulfilling its proper and appropriate functions to best protect consumers” and to…

MoFo ReEnforcement: The Enforcement Blog

CFPB Amends Prepaid Accounts Rule and Delays its Effective Date

By Obrea Poindexter, Jeremy Mandell & Amanda Mollo

January 29, 2018

On January 25, 2018, the CFPB finalized amendments to its final Prepaid Accounts Rule, which was published in November 2016. The Bureau stated that the 2018 Amendments finalize revisions proposed in June 2017 “generally as proposed, with certain modifications.” The 2018 Amendments address some of the issues raised by industry and delay the effective date for all provisions of the Final Rule until April 1, 2019. Read our client alert.…

MoFo ReEnforcement: The Enforcement Blog

CFPB Unveils Prototype Model Forms for Overdraft

By Rick Fischer, Oliver Ireland & Amanda Mollo

August 7, 2017

On August 4, 2017, the CFPB released four “prototype” model overdraft disclosure forms styled under its “Know Before You Owe” initiatives with a press release. The CFPB said the forms were designed to clarify the risks and costs of overdraft coverage for consumers. The press release and forms were accompanied by a report entitled Data Point: Frequent Overdrafters, highlighting the habits of the small group of consumers who initiated the most overdrafts per year. Read our…

MoFo ReEnforcement: The Enforcement Blog

Supreme Court “Expresses” Unanimous View That Credit Card Disclosure Rules Regulate Speech

By Obrea Poindexter, Marc Hearron & Amanda Mollo

April 3, 2017

On March 29, 2017, the U.S. Supreme Court held that a New York law restricting the way merchants may communicate prices to their customers regulates speech and, thus, is subject to review under the First Amendment. Specifically, the Court held that New York General Business Law § 518 (“Section 518”) should not be viewed as regulating prices, which is permissible regulation of conduct, because Section 518 does not require merchants to sell products or services at any…

MoFo ReEnforcement: The Enforcement Blog

CFPB Requests Information Regarding Data Aggregation Services

By Obrea Poindexter, Don Lampe, Jeremy Mandell & Amanda Mollo

November 22, 2016

On November 17, 2016, the CFPB held a field hearing in Salt Lake City, Utah, and published a Request for Information (“RFI”) regarding access to consumer financial account data. Through the RFI, the CFPB is seeking information regarding consumers’ ability to access, control and share personal financial data relating to them in a usable electronic form. Such access includes access by a third party authorized by the consumer in connection with a product or service…

MoFo ReEnforcement: The Enforcement Blog

Whither the CFPB? In Uncertain Times, Rep. Hensarling’s Vision May See New Life

By Don Lampe & Amanda Mollo

November 21, 2016

Given the outcome of the presidential election, the focus is now on President-Elect Trump’s campaign promises to scale back the Dodd-Frank Act and pursue deregulation of financial services. As of now, little is known about specific actions the new administration will pursue after inauguration. There is, however, a template for reform, namely, the Financial Creating Hope and Opportunity for Investors, Consumers and Entrepreneurs Act, H.R. 5983, a substitute version of which was approved by the…

Amanda Mollo

CFPB Issues RFI on Guidance and Implementation Support

CFPB Issues RFI on Inherited Regulations

CFPB Requests Feedback on Rulemaking Process

SEC Breaks Silence on Certain Cryptocurrency Exchanges

With CID Request, CFPB Follows Through on Plan to Review Functions

CFPB Amends Prepaid Accounts Rule and Delays its Effective Date

CFPB Unveils Prototype Model Forms for Overdraft

Supreme Court “Expresses” Unanimous View That Credit Card Disclosure Rules Regulate Speech

CFPB Requests Information Regarding Data Aggregation Services

Whither the CFPB? In Uncertain Times, Rep. Hensarling’s Vision May See New Life

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