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23 Jan 2023, 5:42 am
Among the various provisions of the D&O insurance policy, one of the most litigated provisions is the Insured vs. [read post]
5 Jan 2023, 6:13 am
But the Consolidated Appropriations Act for 2023, which did receive the President’s signature on December 29, 2022, included at least one substantive section dealing with the FOIA. [read post]
8 Dec 2022, 7:29 am
The Act would make the following changes to current law: The BCHA provision that excepts ILCs from the definition of a “bank” would be amended to limit the exception to an ILC (1) that has been approved to receive FDIC deposit insurance on or before September 23, 2021, or (2) with a deposit insurance application pending on September 23, 2021 that is approved before September 23, 2023 by a 2/3 vote of FDIC Directors and for which the FDIC… [read post]
7 Dec 2022, 8:36 am
Generally, the participants agreed that rulemaking is valuable in order to receive and include industry feedback in rules and guidance. [read post]
29 Nov 2022, 10:08 am
However, if Zelle adopts its new rules, the other P2P payment providers will receive enormous pressure to follow suit. [read post]
29 Nov 2022, 4:13 am
Can an agency properly invoke the deliberative process privilege to shield internal deliberations over a sham memo requesting that another agency take action, knowing that the recipient agency will use the request to hide the real reason for its contemplated action? [read post]
22 Nov 2022, 11:30 am
Pointing to a growth in consumer complaints related to crypto-assets, on November 10th, 2022, the Consumer Financial Protection Bureau (the “CFPB”) released a Complaint Bulletin, which analyzed in excess of 8,300 consumer complaints that the CFPB had received related to crypto-assets. [read post]
27 Oct 2022, 1:24 pm
Pursuant to the Dodd-Frank Act, the CFPB receives its funding through requests made by the CFPB Director to the Federal Reserve, subject to a cap equal to 12% of the Federal Reserve’s budget, rather than through the Congressional appropriations process. [read post]
20 Oct 2022, 9:47 pm
Under the current funding mechanism, the CFPB receives its funding through the Federal Reserve, not through a congressional provision of budget authority to the agency. [read post]
A new dark cloud descends: Fifth Circuit panel rules that CFPB funding mechanism is unconstitutional
20 Oct 2022, 11:46 am
Pursuant to the Dodd-Frank Act, the CFPB receives its funding through requests made by the CFPB Director to the Federal Reserve, subject to a cap equal to 12% of the Federal Reserve’s budget, rather than through the Congressional appropriations process. [read post]
19 Oct 2022, 2:14 pm
Is it enjoining the CFPB from receiving unappropriated funds? [read post]
18 Oct 2022, 11:20 am
To receive a non-objection, an institution must demonstrate that it can conduct the proposed activity safely, soundly, and fairly. [read post]
17 Oct 2022, 3:37 pm
In the past, the CFPB seemingly deferred to other regulators, such as the Federal Reserve Board and the FDIC, which entered into settlement agreements with service providers and banks over their allegedly unfair and deceptive practices in connection with the solicitation and operation of student accounts. [read post]
29 Sep 2022, 10:22 am
Populus contrasts the narrower missions and authority of the Federal Reserve, FDIC, and OCC, which are also self-funded. [read post]
21 Sep 2022, 7:57 am
In sharp contrast, according to the CFPB’s arbitration study, in 87% of the 562 class actions that were studied, the putative class members received no benefits whatsoever. [read post]
24 Aug 2022, 9:01 pm
Gruenberg of the Federal Deposit Insurance Corporation (“FDIC”) released the FDIC’s priorities for 2022, which included “[a]ddressing the financial risks that climate change poses to banking organizations and the financial system. [read post]
23 Aug 2022, 3:03 pm
After receiving the letter, Mr. [read post]
4 Aug 2022, 5:09 am
(While not expressly stated by the FDIC, the FDIC would likely expect such review and monitoring to include whether a non-bank partner has taken the steps suggested by the FDIC to reduce consumer confusion.)Insured banks should have appropriate risk management policies and processes to ensure that any services provided by, or deposits received from any third-party, including a crypto company, comply with all laws and regulations.Because the… [read post]
4 Aug 2022, 5:01 am
For cybersecurity vendors, this would place them on a select list of cybersecurity companies that receive specialized alerts and reports of cyber threat intelligence directly from the federal government. [read post]
29 Jul 2022, 3:30 am
In addition, broker-dealers must belong to the Securities Investor Protection Corporation (SIPC), which provides an insurance scheme whereby customers of failed broker-dealers may receive up to $500,000 from the SIPC fund. [read post]