The American Bar Association proposed Resolution 104B this past July to urge policymakers to adopt specific regulations governing auto dealerships and vehicle financing.  While the Resolution failed to win approval, it is not necessarily dead.

As proposed, Resolution 10B would do five things:

  1. Urge federal, state, local, territorial, and tribal governments to “adopt and enforce

On July 31, 2018, the Office of the Comptroller of the Currency (“OCC”) announced its intent to accept applications for special purpose national bank charters from eligible non-depository financial technology (“Fintech”) companies.[1] This announcement coincides with the release of a Treasury Department report supporting financial innovation and the regulation of nonbank financial entities.[2] 

In mid-May 2018, per multiple reports, John Michael “Mick” Mulvaney, the acting director of the Consumer Financial Protection Bureau, announced plans to fold the CFPB’s Office of Students and Young Consumers into its preexisting Office of Financial Education, itself a part of this agency’s Consumer Education and Engagement Division. During this reorganization, the

We are proud to announce that Troutman Sanders partner David Anthony will be a featured speaker at the Practising Law Institute’s 23rd Annual Consumer Financial Services Institute at the Practising Law Institute (PLI) Center in New York City on March 26-27, 2018.

In its 23rd year, topics will focus on a broad array of recent

On Thursday, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) issued its first no-action letter to Upstart Network, Inc., an online lender. The no-action letter green-lights the lender’s use of alternative data in marketing and pricing decisions. In exchange, Upstart will report lending and compliance information to the CFPB.

UPSTART’S MODEL

California-based Upstart provides an

On April 25, the Consumer Financial Protection Bureau held its Spring 2017 Community Bank Advisory Council meeting in Washington.  The purpose of the meeting was to allow representatives from community banks an opportunity to provide additional input on the Bureau’s Request for Information (“RFI”) on the use of alternative data to assess creditworthiness of consumers

Join Troutman Sanders Partners James W. Stevens and Alan D. Wingfield on Thursday, February 9 at 12 p.m. ET for a complimentary webinar to discuss current trends and outlook for the key fair lending issues of redlining and disparate impact.

Specific topics of discussion include the basics of federal regulators’ theories and methodologies in assessing

The Federal Deposit Insurance Corporation (“FDIC”) is seeking comment on proposed examination guidance for Third-Party Lending. [1] The proposed guidance, issued July 29, provides banks with safety, soundness and consumer compliance measures to be followed when lending through a business relationship with a third party. The proposed guidance will apply to all banks that engage

In a letter dated July 21, Senators Sherrod Brown (D-Ohio) and  Jeffrey Merkley (D-Ore.), on behalf of the Committee on Banking, Housing, and Urban Affairs (the “Committee”), asked the heads of several federal agencies to provide the Committee with information concerning their understanding of the role of fintech in the consumer financial services

On June 22, 2016, the Consumer Financial Protection Bureau (“CFPB”) issued its third update to its exam procedures for mortgage servicers.  In its press release, the CFPB stated that mortgage servicers should “note a greater emphasis” on complaint handling, responses to requests by borrowers, and fair lending issues.  According to the CFPB, the update