As we head into the July 4th holiday and the heart of summer approaches, we have updated our brief deck summarizing the leadership and staffing changes among federal financial regulators, including announced nominations, resignations and expiring terms. The first slide summarizes the state of play for the agencies’ principals;
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CFPB
Davis Polk Financial Services Regulatory Reform Tool—Summer Beach Read Edition
Posted in Administrative Law, Anti-Money Laundering, Bank Capital, Bank Regulation, CFPB, CFTC, Community Reinvestment Act, Cost-Benefit Analysis, Dodd-Frank, Economic Sanctions, FDIC, Federal Reserve, FSOC, Legislation, Liquidity, OCC, OFAC, Stress Testing, Swap Regulation, TLAC, U.S. Basel III, U.S. Congress, Volcker Rule
Financial services regulatory reform in 2018 continues to evolve. For those of you who have been thinking you might catch up over the summer lull, here is the summer beach read edition of our reference tool, which provides context and summarizes current developments across a range of key regulatory areas,…
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SDNY Weighs In on the Constitutionality of the CFPB’s Structure
Posted in CFPB
Arguments surrounding the constitutionality of the CFPB’s structure, never fully put to rest despite the D.C. Circuit’s en banc decision in PHH v. CFPB, are back in the headlines this week. Yesterday, Senior United States District Judge Loretta A. Preska of the Southern District of New York issued a…
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Status of Financial Regulatory Leadership Changes
By Paul E. Means on
As mid-year 2018 approaches, we have updated our brief deck summarizing the leadership and staffing changes among federal financial regulators, including announced nominations and resignations and expiring terms. The first slide summaries the state of play for the principals, and the later slides provide a deeper dive on an agency-by-agency…
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Davis Polk Financial Services Regulatory Reform Tool—May 2018
Financial services regulatory reform in 2018 is complex and evolving. To assist in navigating this landscape, we have prepared a reference tool that provides context and summarizes current developments across a range of key regulatory areas, agencies and actors. We will continue to track these issues and provide updated versions…
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Davis Polk Financial Services Regulatory Reform Tool–March 2018
Financial services regulatory reform in 2018 is complex and evolving. To assist in navigating this landscape, we have prepared a reference tool that provides context and summarizes current developments across a range of key regulatory areas, agencies and actors. We will continue to track these issues and provide updated versions…
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D.C. Circuit Decides PHH v. CFPB–Is the Supreme Court Next?
By Randall D. Guynn & Margaret E. Tahyar on
Posted in CFPB, PHH v. CFPB
The question we are being asked most often is whether PHH v. CFPB is headed to the Supreme Court. The D.C. Circuit’s en banc decision that the current structure of the CFPB—an agency headed by a single director, removable by the President only for “inefficiency, neglect of duty or malfeasance…
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The CFPB and the Rule of Law
The Mulvaney Memo on the CFPB and the rule of law is one of the most remarkable documents to be published by an agency head in many years. It signals a deep commitment to the rule of law as a philosophical concept and as an important brake on agency discretion…
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The CFPB’s Call for Evidence: An Indication of Further Regulatory Rebalancing
Posted in CFPB, Guidance & FAQs
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,…
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Thoughts on Suit to Vacate CFPB Arbitration Rule
Posted in Administrative Law, Bank Regulation, CFPB, Dodd-Frank, Final Rule, PHH v. CFPB, U.S. Congress
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…
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