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MoFo Reenforcement The Enforcement Blog

Tag Archives: Federal Reserve Board

Faster Payments Task Force Sets Goals and Recommendations for Faster Payments by 2020

Posted in Electronic Payments, Mobile Payments

On July 21, 2017 the Federal Reserve’s Faster Payments Task Force released the Faster Payments Task Force Final Report Part Two. The Final Report is a follow-up to Part One of the Faster Payments Task Force Final Report, which was published in January 2017 and provided an overview of the Task Force’s objectives and a… Read More

Whither the CFPB? In Uncertain Times, Rep. Hensarling’s Vision May See New Life

Posted in Regulatory Developments

Given the outcome of the presidential election, the focus is now on President-Elect Trump’s campaign promises to scale back the Dodd-Frank Act and pursue deregulation of financial services. As of now, little is known about specific actions the new administration will pursue after inauguration. There is, however, a template for reform, namely, the Financial Creating… Read More

Federal Banking Agencies Signal Enhanced Cyber Standards

Posted in Privacy, Regulatory Developments

On October 19, 2016, the Federal Deposit Insurance Corporation, the Federal Reserve Board and the OCC (collectively, the Agencies) released an Advanced Notice of Proposed Rulemaking (ANPR) laying out a framework for enhanced cyber risk management standards that the Agencies are considering requiring of certain “large and interconnected” financial institutions.  The Agencies have not yet proposed… Read More

#ThrowbackThursday: Federal Reserve Board Issues Final CARD Act Rule on Penalty Fees and Rate Reevaluations

Posted in Credit Cards, Regulatory Developments

In June 2010, Morrison & Foerster published the client alert “Federal Reserve Board Issues Final CARD Act Rule on Penalty Fees and Rate Reevaluations.” Summary: Adding yet another layer of credit card regulation, the Federal Reserve Board issued a final rule to implement the reasonable penalty fee and rate reevaluation provisions of the “Credit Card… Read More

#ThrowbackThursday: UDAP Final Rules and Board Regulatory Actions

Posted in Credit Cards, Regulatory Developments, UDAAP

Originally published as a Morrison & Foerster client alert in December 2008. UDAP Final Rules The National Credit Union Administration (“NCUA”) approved a joint final rule addressing unfair or deceptive acts or practices (“UDAP”) relating to credit cards written by the Board of Governors of the Federal Reserve System (“Board”), the Office of Thrift Supervision… Read More

Higher One, Inc. Enforcement Actions Remind Nonbank Service Providers of Their Legal Obligations When Partnering With Banks

Posted in CFPB, Enforcement Actions, UDAAP

On December 23, 2015, the Federal Reserve Board (“Federal Reserve”) and the Federal Deposit Insurance Corp. (“FDIC” and, collectively with the Federal Reserve, the “Agencies”) announced settlements with Higher One, Inc. (“Higher One”) for alleged violations of the prohibition against deceptive acts and practices under Section 5 of the Federal Trade Commission Act. In conjunction… Read More

Supreme Court to Determine Whether ECOA Allows Spousal Guarantors to Challenge Liability

Posted in Fair Lending

On March 2, 2015, the Supreme Court of the United States granted certiorari in Hawkins v. Cmty. Bank of Raymore, 761 F.3d 937 (8th Cir. 2014), cert. granted, No. 14-520, 2015 U.S. LEXIS 1635 (U.S. Mar. 2, 2015)—on appeal from the Eighth Circuit—to decide whether certain guarantors are excluded from the definition of “applicant” under… Read More

When Is “Payment Authorization” the Same as a “Payment”? Seventh Circuit Weighs In

Posted in CFPB, Electronic Payments, Mortgage

A divided Seventh Circuit found that the Truth in Lending Act (TILA), 15 U.S.C. § 1601 et seq., requires mortgage servicers to credit online electronic payments on the day the customer authorizes the payment, despite not actually receiving the payment at that time. Fridman v. NYCB Mortg. Co., LLC, No. 14-2220 (7th Cir. Mar. 11,… Read More