Today, the House of Representatives passed, by a 254-161 vote, the Systemic Risk Designation Improvement Act of 2016 (the “Act”), which is designed to relieve regional and specialty b...
In a recently released white paper, former Small Business Administration head Karen Mills and former Economic Council aide Brayden McCarthy call for regulatory action in the small busines...
Those who are not closely following PHH v. CFPB may not be aware that the panel decision is not final and effective. PHH is the D.C. Circuit decision holding that the current structure of...
The transition of power from one Administration to another, especially when it involves a change of party, is governed both by law and custom. Both may be changing. In this post, we exami...
President-Elect Trump’s transition website promises to “dismantle the Dodd-Frank Act and replace it with new policies to encourage economic growth and job creation.” To help our cl...
This blog post sets out how rollback of the Dodd-Frank Act or its implementing regulations might work. President Elect Trump’s administration and the new Republican majority in Congress...
Editor’s note: this post has been edited since the date of its original publication.
On October 26, 2016, the Office of the Comptroller of the Currency (the “OCC”) announced initiat...
In October 2016, the U.S. federal banking agencies jointly issued an advance notice of proposed rulemaking regarding enhanced cyber risk management standards (the “Enhanced Standards”...
Not surprisingly, the many media and political reactions to the PHH Corp. v. CFPB decision have reflected the competing stakeholder interests around every aspect of the CFPB.In this memor...
In September 2016, the New York State Department of Financial Services (the “NYDFS”) proposed new cybersecurity regulations (the “Proposed Rules”) for banks, insurance companies a...
