Yesterday, five federal agencies – the Federal Reserve Board, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency, and the Bureau of Consumer Financial Protection – issued a two-page, joint statement on the role of supervisory guidance for regulated institutions. Although brief, the joint statement is significant. Read our client alert.…

On August 17, 2018, the Bureau of Consumer Financial Protection published a final rule amending its Regulation P to include an exception to the Gramm-Leach-Bliley Act annual privacy notice obligation. Nearly three years ago, the Fixing America’s Surface Transportation Act (FAST Act) amended the GLBA to provide for such an exception. The CFPB has now caught up in order to ensure that Regulation P is consistent with the GLBA as amended. Although the final rule…

Two key federal government announcements were made on July 31, 2018 related to fintech issues. First, the U.S. Department of the Treasury issued a press release announcing a report entitled “Nonbank Financials, Fintech, and Innovation.” The Report is the fourth and final in a series of reports prepared by Treasury in response to President Trump’s February 2017 Executive Order 13772. In addition, the Office of the Comptroller of the Currency announced that it would begin…

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…

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.…

On March 21, 2018, a CFPB Request for Information on the CFPB’s adopted regulations and rulemaking authorities was published in the Federal Register. This RFI is the eighth in a series that, collectively, solicits public input on the full scope of the Bureau’s operations. In this latest RFI, the CFPB seeks input on whether it should “amend those rules it has promulgated since [the Bureau’s 2011] creation or issue certain new rules.” Comments are due by…

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.…