Sam Adriance

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CFPB Issues RFI on Credit Card Market

On March 10, 2017, the Consumer Financial Protection Bureau (“CFPB” or the “Bureau”) issued a request for information regarding the consumer credit market (the “RFI”). Section 502 of the Credit Card Accountability Responsibility and Disclosure Act of 2009 (the “CARD Act”) requires the CFPB to conduct a biennial review of the credit card market, which … Continue Reading

D.C. Circuit Grants Rehearing En Banc in PHH

The D.C. Circuit today granted rehearing en banc in PHH Corp., et al. v. Consumer Financial Protection Bureau (“PHH”), vacating the prior order that, among other things, found the Consumer Financial Protection Bureau’s (“CFPB”) structure unconstitutional. The court directed the parties to brief a set of questions related to: the constitutionality of the Bureau’s structure; … Continue Reading

President Trump Signs First Congressional Review Act Disapproval Resolution in 16 Years

On February 14, 2017, President Donald Trump signed a resolution nullifying a Securities and Exchange Commission (“SEC”) regulation that required energy companies to disclose foreign payments. This marks the first successful use of the Congressional Review Act (“CRA”) procedure in 16 years, and only the second successful use since the statute passed in 1996.  Several … Continue Reading

House Freedom Caucus Takes Aim at Financial Regulations

On December 14, 2016, House Freedom Caucus Chairman Mark Meadows released a special report (the “Report”) detailing over 200 rules, regulations, and executive orders the Caucus recommends that President-Elect Donald Trump should examine, revoke, or issue in his first 100 days in office. The report targets for repeal a diverse set of regulations finalized or … Continue Reading

Financial Stability Board Publishes 2017 Roadmap for Correspondent Banking

On December 19, 2016, the Financial Stability Board (“FSB”) issued its end-of-2016 progress report regarding its action plan to assess and address the decline in correspondent banking. The report sets out a roadmap the FSB intends to follow in 2017 in response to the decline of correspondent banking, a critical part of the global payments … Continue Reading

Post-Election Outlook for Financial Regulatory Agencies: The Consumer Financial Protection Bureau

The transition to a new administration with the election of Republican Donald J. Trump as President, along with continued Republican control of the Senate and House of Representatives, promises to bring substantial change to each of the federal financial regulatory agencies. Changes in leadership at those agencies will likely result in substantial changes in policy … Continue Reading

GAO Issues Report on Fed Stress Tests

On Tuesday, the Government Accountability Office (“GAO”) issued a report to the House Financial Services Committee (the “Report”) regarding stress tests conducted by the Board of Governors of the Federal Reserve System (the “Fed”). The Report grew out of a 2014 request from Rep. Jeb Hensarling, Chairman of the House Financial Services Committee, for the … Continue Reading

SEC Leaders Discuss Fintech Regulation

At the inaugural Financial Technology Forum hosted by the Securities and Exchange Commission (the “SEC”) November 14, 2016, SEC Chairwoman Mary Jo White and Commissioner Michael Piwowar gave remarks addressing the future of fintech regulation and the role of the SEC in such regulation. Both Chairwoman White and Commissioner Piwowar emphasized the potential benefits and … Continue Reading
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