Last Friday, the U.S. Supreme Court agreed to decide when a right of action first accrues for an Administrative Procedure Act (APA) challenge to a final rule issued by a federal agency—when the final rule is issued or when the
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Alan Kaplinsky authors American Banker article on CFPB v. CFSA
Tomorrow, the U.S. Supreme Court will hear oral argument in CFPB v. CFSA, in which the question presented is whether the CFPB’s funding mechanism violates the Appropriations Clause of the U.S. Constitution.
In an article requested by and published today…
CFPB Releases 2022 Mortgage Market Activity and Trends Report
The CFPB recently released a report entitled Data Point: 2022 Mortgage Market Activity and Trends based on 2022 data reported by lenders under the Home Mortgage Disclosure Act (HMDA).
The CFPB addresses various 2022 lending results, with many results reflecting…
CFPB Releases Updated 1071 Small Business Lending FAQs
On September 14, 2023, the CFPB released Frequently Asked Questions (FAQs) regarding the Small Business Data Collection Rule (the “Rule”). These FAQs are in addition to the set published in June 2023, which are dated. Some, but not all, of…
CFPB Continues to Expand Its Scrutiny of Higher Education with New Report on College and Postsecondary School Tuition Plans
The CFPB recently released a report regarding higher education tuition payment plans that discusses prevailing practices and highlights certain CFPB concerns regarding consumer impact. The CFPB’s report was based upon (a) a review of hundreds of postsecondary school and college…
This week’s podcast episode: Federal court rules CFPB cannot use UDAAP authority to regulate discrimination: a close look at the decision and its implications
In March 2022, the Consumer Financial Protection Bureau announced that it had revised its examination manual to instruct its examiners to apply the “unfairness” standard under the Consumer Financial Protection Act to conduct considered to be discriminatory, whether or not…
FinCEN Issues Small Entity Compliance Guide for Corporate Transparency Act

The Financial Crimes Enforcement Network (“FinCEN”) has published a Small Entity Compliance Guide (the “Guide”) for beneficial ownership information (“BOI”) reporting under the Corporate Transparency Act (“CTA”), as well as updated FAQs regarding CTA compliance.
The Guide contains six chapters…
FinCEN Issues Small Entity Compliance Guide for Corporate Transparency Act

The Financial Crimes Enforcement Network (“FinCEN”) has published a Small Entity Compliance Guide (the “Guide”) for beneficial ownership information (“BOI”) reporting under the Corporate Transparency Act (“CTA”), as well as updated FAQs regarding CTA compliance.
The Guide contains six chapters…
FinCEN Issues Small Entity Compliance Guide for Corporate Transparency Act

The Financial Crimes Enforcement Network (“FinCEN”) has published a Small Entity Compliance Guide (the “Guide”) for beneficial ownership information (“BOI”) reporting under the Corporate Transparency Act (“CTA”), as well as updated FAQs regarding CTA compliance.
The Guide contains six chapters…
FinCEN Issues Small Entity Compliance Guide for Corporate Transparency Act

The Financial Crimes Enforcement Network (“FinCEN”) has published a Small Entity Compliance Guide (the “Guide”) for beneficial ownership information (“BOI”) reporting under the Corporate Transparency Act (“CTA”), as well as updated FAQs regarding CTA compliance.
The Guide contains six chapters…