The CFPB’s announcement of a call for evidence is a welcome sign that the new leadership of the agency is thinking seriously about how it implements its mission. In the coming weeks the CFPB will publish a series of Requests for Information (RFIs) seeking public comment on the CFPB’s enforcement, … Read More

Many have commented on the suit filed last week challenging the CFPB’s arbitration rule, but few have considered what impact, if any, the suit could have on the fast-approaching compliance date of March 19, 2018.

As a reminder, the Chamber of Commerce and other trade associations filed a long-anticipated suit … Read More

In the run up to the August recess, the Senate confirmed 76 of President Trump’s nominees last week, including a handful of senior personnel at various financial regulatory agencies. As we continue to track personnel changes at these agencies, we have updated our brief deck summarizing the leadership and staffing … Read More

Since the CFPB issued its Arbitration Rule in July, most commentators have focused on ways the rule may be blocked from going into effect. Chief among these is the possibility that Congress will vote to overturn the rule under the Congressional Review Act, and the House did promptly vote in … Read More

Friday marks the seventh anniversary of the Dodd-Frank Act.  The outlook for financial regulation, and Dodd-Frank, has fundamentally shifted over the past year.  Since President Trump’s election and his promise to “dismantle” Dodd-Frank, implementation of the 2010 law has been put into pause mode by all of the financial regulators … Read More

Yesterday afternoon, the CFPB issued a final rule that, once it becomes effective, is designed to prohibit providers of certain consumer financial products or services from using pre-dispute arbitration clauses to bar consumers from participating in class action lawsuits.  Although covered providers will still be permitted to include mandatory arbitration … Read More

There has been a slow start to financial regulatory reform under the Trump Administration, but the conversation is now changing in ways that are serious and thoughtful. This note highlights the key themes that we believe are important for mid-sized and regional banks in light of recent personnel announcements, … Read More

A revised version of the Financial CHOICE Act (commonly referred to as CHOICE Act 2.0) was passed by the House Financial Services Committee last week on a strictly partisan vote and will now move to a vote by the full House of Representatives. The HFSC majority has provided both an … Read More