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Lucille Bartholomew

Associate

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CFPB Proposes Extension of Effective Date for Prepaid Accounts Final Rule

On March 9, 2017, the CFPB released a proposal to delay the effective date for certain provisions of the prepaid accounts final rule for six months, from October 1, 2017, to April 1, 2018.  In its proposal, the CFPB indicated that the proposed extension was prompted by industry concerns about constraints on the ability to … Continue Reading

Solicitor General Requests Extension to File Amicus Brief for PHH v. CFPB and Signals Potential Shift in Support for the CFPB

As we previously discussed, on February 16, 2017, the D.C. Circuit granted rehearing en banc in PHH v. CFPB and vacated the holding from the three-judge panel that the CFPB’s single director structure was unconstitutional. Through an unopposed motion filed on March 3, 2017, the Office of the Solicitor General (“SG”) requested an extension to file … Continue Reading

Democratic Senators Send Letter to Colleagues Arguing Against Restructuring the CFPB as a Commission

On January 31, 2017, Senators Sherrod Brown (D-OH) and Elizabeth Warren (D-MA) sent a letter to Democratic Senators arguing that the single director structure of the Consumer Financial Protection Bureau (“CFPB”) should not be replaced with a five-member commission.  Specifically, the Senators warned that attempts to restructure the CFPB are intended “to prevent the agency … Continue Reading

The Federal Reserve Board Issues Final Rule Amending Capital Plan and CCAR Stress Test Rules

On January 30, 2017, the Board of Governors of the Federal Reserve System (the “Federal Reserve Board”) released a final rule amending its capital plan and Comprehensive Capital Analysis and Review (“CCAR”) stress testing rules. The final rule addresses the following key issues, among others: Qualitative Assessments.  Under the final rule, “large and noncomplex bank … Continue Reading

Comptroller of the Currency Thomas J. Curry Delivers Remarks Regarding Interagency Collaboration (and the OCC’s Relationship with the CFPB)

On October 25, 2016, OCC Comptroller of the Currency Thomas J. Curry delivered remarks to a group of bank regulators at the tenth annual FDIC Accounting and Auditing Conference.  The remarks, addressing the importance of interagency collaboration, provide insight into how Comptroller Curry views the OCC’s relations with the other banking agencies. In his remarks, … Continue Reading

Cordray Remarks at Mortgage Bankers Association Address PHH Decision

On October 25, 2016, CFPB Director Richard Cordray delivered remarks to the Mortgage Bankers Association regarding the recovery of the mortgage industry.  Director Cordray discussed several of the CFPB’s mortgage-related initiatives, including the reporting requirements under Regulation C, which implements the Home Mortgage Disclosure Act, and the “Know Before You Owe” mortgage disclosure rule. Director … Continue Reading
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