Lauren Abbott

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Michael E. Bleier, a partner in Reed Smith’s Financial Services Regulatory Group, was recently quoted by the National Law Journal regarding the long-awaited Volcker Rule that was finalized by federal regulators December 10. Among other things, the Volcker Rule – named after former Federal Reserve Chairman Paul Volcker – prevents financial institutions from making short-term proprietary trades and requires new certifications from corporate officers. Michael was quoted as saying that any lawsuit challenging the…
Len Bernstein, chair of Reed Smith’s Financial Services Regulatory Group and Managing Partner of the firm’s Philadelphia office, was recently quoted by the Legal Intelligencer regarding the extensive preparation regulatory lawyers and the mortgage industry have done to assist mortgage lenders and servicers in dealing with the changes in the regulatory landscape largely effective in January 2014. The Consumer Financial Protection Bureau (“CFPB”) began its mortgage regulatory avalanche in early 2013 with the issuance of…
On September 14, 2013, the Pennsylvania Department of Banking and Securities (“DOBS”) published a notice of proposed rulemaking in the Pennsylvania Bulletin to implement an updated assessment schedule for Pennsylvania state-chartered financial institutions, trust companies and credit unions. 43 Pa.B. 5455. The Department of Banking and Securities Code, 71 P.S. 733-101 et seq., provides the DOBS with the authority to assess institutions the cost of examination or investigation of that entity. 71 P.S. § 733-204.…
On July 2, 2013, Pennsylvania Governor Tom Corbett signed into law HB 1124, which amends the Mortgage Licensing Act (“MLA”), 7 Pa. C.S. § 6101 et seq. The amendments to the MLA take effect August 31, 2013, which is 60 days from the date the governor signed the bill. While some of the amendments will be viewed positively by the mortgage industry, the restriction on how far mortgage originators may live from their assigned offices…
In April 2013, Representative Scavello (R. Monroe County) and others introduced HB 1124, which would amend the Mortgage Licensing Act (“MLA”), 7 Pa. C.S. 6101 et seq. HB 1124 was passed by the House on April 24, 2013 and is currently with the Senate. The bill has the support of the Department of Banking and Securities. There is a good chance that HB 1124 will be signed into law by the end of 2013. The…
On December 24, 2012, three bills, H.B. 2368, H.B. 2369, and H.B. 2370, became effective. These new laws greatly expand the regulatory and enforcement tools available to the Pennsylvania Department of Banking and Securities (“Department”), bringing Pennsylvania law into compliance with the Dodd-Frank Act and modernize, where necessary, Pennsylvania’s Banking Code. As a result of this legislative package, Pennsylvania may become a more desirable location to conduct banking business while ensuring that its laws and…
The Consumer Financial Protection Bureau (“CFPB”) announced May 24, 2012, that it was seeking comments from the public on an Advance Notice of Proposed Rulemaking (“Notice”) regarding general purpose reloadable prepaid cards (“GPR cards”). The CFPB described a GPR card as a product that is “issued for a set amount in an exchange for payment made by a consumer” and to which a consumer can add funds. GPR cards can also be in the form…
On March 26, 2012, the Consumer Financial Protection Bureau (“CFPB”) filed an amicus curiae brief in Rosenfield v. HSBC Bank, USA, et al. in the United States Court of Appeals for the 10th Circuit in support of the consumer-appellant, arguing that courts have not correctly interpreted the federal Truth-in-Lending Act (“TILA”) regarding how long a consumer has to rescind a mortgage loan. This brief is the first of four briefs that the CFPB intends to…
On March 14, 2012, the Financial Crimes Enforcement Network (“FinCEN”) released the new Registration of Money Services Business (“RMSB”), FinCEN Report 107. The newly released RMSB is intended to supplement two notable 2011 rulemakings. First, in a July 18, 2011, rulemaking, FinCEN clarified that certain foreign-located persons engaging in MSB activities within the United States fall within FinCEN’s definition of an MSB, and therefore must comply with FinCEN requirements, including the requirement to register with…
On February 14, 2012, the Federal Reserve Board (“Board”) announced its approval of Capital One Financial Corporation (“Capital One”) to acquire the shares of ING Bank, fsb (“ING”). In its order approving the acquisition, the Board reaffirmed its test for determining financial stability in light of the new criteria required by Dodd-Frank to the analysis of expansion applications pursuant to the Bank Holding Company Act (12 U.S.C. §§ 1842 and 1843) (“BHC Act”), which was…