Editor's Note

We would like to introduce you to a new initiative from our firm to provide a regular report of key financial services developments to our clients. There would be no charge for this service and we would email every two weeks. Also, if you have any feedback we'd be happy to incorporate it! Finally, if you have any questions regarding the developments detailed below, please feel free to reach out to your relationship contact and we'd be happy to assist. Thank you!

The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on: (1) the source of the development (regulator, legislative body, etc.), (2) the subject matter (consumer lending, money transmission, capital markets, etc.), and (3) the general issue covered.

Regulatory Developments

Enforcement and Litigation

• Federal Reserve Board. Safety and Soundness & Counterparty Credit Risk. FRB announced a consent order and a $268.5 million fine to a foreign bank for alleged misconduct by a subsidiary regarding its alleged unsafe and unsound counterparty credit risk management practices with its former counterparty.
• Consumer Financial Protection Bureau. Auto Loans & Debt Collection. CFPB filed a suit in federal court against an auto loan servicer for allegedly violating 12 U.S.C. §§ 5531(a), 5536(a)(1)'s (Consumer Financial Protection Act) prohibition on unfair and deceptive practices by wrongfully disabling borrowers' vehicles, improperly repossessing vehicles, double-billing borrowers for insurance premiums, and failing to return millions of dollars in refunds to consumers.

Research and Analysis

Michael Buckalew is a regulatory analyst with Davis Wright Tremaine LLP.