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Articles by Robin Nunn
Abusive Acts and Practices: Putting the CFPB’s Policy Statement into Practice
The Consumer Financial Protection Bureau (CFPB) released a second iteration of its Policy Statement on Abusive Acts and Practices (Policy Statement) on April 3, 2023, giving insight into its current thinking on the abusiveness doctrine, laying the groundwork for supervision and enforcement, and giving clear guidance to state enforcement authorities pursuing abusive practices cases.
Abusive Acts and Practices: Putting the CFPB’s Policy Statement into Practice
The Consumer Financial Protection Bureau (CFPB) released a second iteration of its Policy Statement on Abusive Acts and Practices (Policy Statement) on April 3, 2023, giving insight into its current thinking on the abusiveness doctrine, laying the groundwork for supervision and enforcement, and giving clear guidance to state enforcement authorities pursuing abusive practices cases.
CFPB Releases Final Small Business Lending Rule
The Consumer Financial Protection Bureau (CFPB, the Bureau) promulgated on March 30 its final rule implementing Section 1071 of the Dodd-Frank Act. The rule requires that covered financial institutions collect and report to the Bureau data on applications for credit by small businesses (those having gross revenue of under $5 million in their latest fiscal year).
CFPB Proposal Targets Limiting Credit Card Late Fees
The Consumer Financial Protection Bureau (CFPB) recently issued a notice of proposed rulemaking to amend Regulation Z (the Proposal), which implements the Truth in Lending Act (TILA), to better ensure that late fees charged on credit card accounts are “reasonable and proportional” to late payments as required under the Credit Card Accountability and Disclosure Act of 2009 (Card Act).
FinCEN Proposes New Rule on Beneficial Ownership Information Access and Safeguards for Corporate Transparency Act | JD Supra
The US Treasury’s Financial Crimes Enforcement Network (FinCEN) recently proposed a new rule (the Proposed Rule) regarding beneficial ownership information access and safeguards pursuant to the Corporate Transparency Act.
FinCEN Proposes New Rule on Beneficial Ownership Information Access and Safeguards for Corporate Transparency Act
The US Treasury’s Financial Crimes Enforcement Network (FinCEN) recently proposed a new rule (the Proposed Rule) regarding beneficial ownership information access and safeguards pursuant to the Corporate Transparency Act.
Fintech Industry Must Transform to Help Underserved Communities
By Robin Nunn Jan. 5, 2023, 9:00 AM Rapid growth of non-bank financial services requires careful regulation to balance competition with access, transparency, and privacy protection. Morgan Lewis’s Robin Nunn considers alternative credit options that can mean the difference between financial well-being and hardship. Alternative credit options can mean the difference between financial well-being and financial hardship for many borrowers.
Fintech Industry Must Transform to Help Underserved Communities
By Robin Nunn Jan. 5, 2023, 9:00 AM Rapid growth of non-bank financial services requires careful regulation to balance competition with access, transparency, and privacy protection. Morgan Lewis’s Robin Nunn considers alternative credit options that can mean the difference between financial well-being and hardship. Alternative credit options can mean the difference between financial well-being and financial hardship for many borrowers.
Emerging Financial Crime Trends, Payment Fraud, and Risk Mitigation: How Banks Can Be Prepared | JD Supra
Consumers’ worldwide adoption of instant, contactless transactions has provided an opportunity for some to take advantage of loopholes and weaknesses in digital systems. Peer-to-peer (P2P) payments fraud, synthetic identities, and cryptocurrency scams are just a few examples in the current trends of financial crimes. Financial institutions, regulators, and technology providers alike are exploring avenues to stay ahead of these developments and prevent fraud.
Updating Community Reinvestment Act Is Key for Financial Inclusion
Photo by Stefan Wermuth/Bloomberg By Robin Nunn June 24, 2022, 8:00 AM Modernizing the Community Reinvestment Act may easily be the most consequential bank regulatory action this year, says Morgan Lewis partner Robin Nunn. The proposal represents a major step forward for modernizing existing regulations to account for the growth of mobile and online banking, she says. She offers takeaways for attorneys representing banks and other financial institutions.
CFPB Spring Supervisory Highlights Detail Agency Findings and Priorities | JD Supra
The Consumer Financial Protection Bureau (CFPB or Bureau) recently released its Spring Supervisory Highlights summarizing findings from supervisory exams it conducted between July and December 2021. The CFPB has made various statements and numerous public-facing communications, including the Supervisory Highlights document, about its mission and priorities.
AGENDA | CPR AM2022
Please check back often for the most up to date information. #cprAM22 All times are Eastern. All programming is subject to change.
What Happened Today at ETHDenver 2022
Source: ETHDenver.com Follow the latest updates from ETHDenver 2022 conference with Cryptonews.com! Disclaimer: The Industry Talk section features insights by crypto industry players and is not a part of the editorial content of Cryptonews.com. ETHDenver is the largest and longest-running ETH event in the world. It is also a member-owned Community Innovation Festival and the first event-based decentralized autonomous organization (DAO) in the world.
Buy Now, Pay Later: Balancing Credit Access With Consumer Protection
United States: Buy Now, Pay Later: Balancing Credit Access With Consumer Protection 17 February 2022 by Eamonn K. Moran and Robin Nunn Morgan Lewis To print this article, all you need is to be registered or login on Mondaq.com. Driven by an increase in online and mobile app shopping during the COVID-19 pandemic, the "buy now, pay later" (BNPL) market has experienced exponential growth.
CFPB’s Probe of Buy Now, Pay Later: What’s the Risk to Consumers?
Due to the pandemic-fueled shift toward online and mobile app shopping, the “buy now, pay later” (BNPL) market has experienced sharpgrowth. BNPL is a type of short-term financing that allows consumers to make purchases and pay off the balance in small installments, often interest-free. In 2021, consumers spent nearly $100 billion in purchases using BNPL programs, up from $24 billion in 2020—a 316% increase.
CFPB Pans Credit Reporting Agency Consumer Complaint Handling | JD Supra
On January 5, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a report detailing consumer complaint deficiencies by the national credit reporting agencies (NCRAs). Specifically, the CFPB found that, in 2021, the NCRAs together reported relief in response to less than 2% of covered complaints, down from nearly 25% of covered complaints in 2019.
Energy Companies Must Prepare Now for New Board Diversity Regulations | JD Supra
The composition of the average company’s board of directors is more varied and unique than ever before. Nonetheless, as a whole, the energy sector lags behind the average publicly traded company in terms of increasing the number of women and underrepresented minorities as board members. A series of new US state legislation and rules promulgated by stock exchanges present energy companies with the challenge of how to comply with board diversity legislation.
President’s Working Group Report: Stablecoin Issuers Should Be Banks; Status as Securities or Commodities Still Unclear | JD Supra
US President Joe Biden’s Working Group on Financial Markets (PWG), along with the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC), released a report on the risks and legislative recommendations for stablecoins, recommending that issuers be limited to insured depository institutions.
Opinion | Mayor Bowser’s harsh plan for D.C.'s homeless encampments must end
Robin Nunn is an advisory neighborhood commissioner in Dupont Circle. Yannik Omictin is an advisory neighborhood commissioner in Foggy Bottom. Peter Wood is an advisory neighborhood commissioner in Adams Morgan. The recently announced Coordinated Assistance and Resources for Encampments (CARE) pilot program has been met with criticism from unhoused D.C. residents and the greater D.C. community.
US Supreme Court Majority Rules No Harm, No Foul in TransUnion LLC v. Ramirez | JD Supra
On June 25, 2021, in TransUnion LLC v. Ramirez, a 5-4 majority of the US Supreme Court appeared to hand another victory to defendants facing lawsuits under federal statutes that impose stiff penalties regardless of proof of injury. The plaintiff argued that he and a certified class were entitled to statutory penalties under the federal Fair Credit Reporting Act (FCRA) because the alleged misreporting of personal information caused concrete injury.
What To Expect From FinCEN's Beneficial Ownership Rules
Law360 (April 20, 2021, 6:33 PM EDT) -- There has been a recent flurry of activity by the U.S. Department of the Treasury in connection with the Corporate Transparency Act, a key component of the Anti-Money Laundering Act of 2020.
FinCEN Releases Advance Notice of Proposed Rulemaking on New Beneficial Ownership Reporting Requirement | JD Supra
The US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) on April 1 took the first step towards implementing the Corporate Transparency Act’s (CTA’s) beneficial ownership reporting requirements, issuing an Advanced Notice of Proposed Rulemaking (ANPRM).
What 2021 Has in Store for Stablecoin | JD Supra
The year 2020 won’t soon be forgotten. Despite the challenges that the COVID-19 pandemic presented on a global scale, 2020 ushered in new ways of thinking about stablecoin, a type of cryptocurrency that attempts to peg its market value to an external reference, such as a fiat currency (like the US dollar) or the price of a commodity (like gold), and has garnered much attention from tech companies, financial services institutions, and policymakers.
How Corporate Transparency Act Could Benefit Finance Cos.
Law360 (December 22, 2020, 3:47 PM EST) -- The Corporate Transparency Act, found within the National Defense Authorization Act, directs the Financial Crimes Enforcement Network to establish and maintain a national registry of beneficial ownership information.
Corporate Transparency Act: How Will It Affect Financial Institutions? | JD Supra
The Corporate Transparency Act, found within the National Defense Authorization Act, directs the Financial Crimes Enforcement Network to establish and maintain a national registry of beneficial ownership information. The legislation is designed to crack down on the use of shell companies to facilitate the laundering of criminal proceeds, but it remains to be seen how implementation of the new law enforcement tool will affect financial institutions’ customer due diligence requirements.
US Lawmakers Propose Stablecoin Regulation | JD Supra
Members of the US Congress announced on December 2 the proposal of a new consumer protection bill to increase the oversight and regulation of existing stablecoin issuers, potential stablecoin issuers, and stablecoin-related service providers.
Consumer Financial Protection Outlook | JD Supra
With only weeks until the US presidential administration changes hands, companies and consumers alike are anticipating what a Biden presidency will mean for consumer financial protection and for the Consumer Financial Protection Bureau (CFPB), the agency charged with overseeing it. Partner Robin Nunn and of counsel Eamonn Moran outline some of the changes that may lie ahead.
Senate Banking Committee Members Propose Fair Access to Financial Services Act | JD Supra
Members of the US Senate Banking Committee recently introduced a bill to create the Fair Access Financial Services Act of 2020, which is aimed to make any practice of discrimination by a financial institution on the grounds of the consumer’s race, color, religion, national origin, or sex (including sexual orientation and gender identity) expressly illegal.
Robin Nunn for Dupont Circle ANC
(Washington Blade file photo by Michael Key) I have been blessed to call Dupont Circle my home for nearly a decade, watching it change and grow before my very own eyes. I have made countless lifelong friends here, and expect to make many more as time goes on. I am proud to call this my home, but it is evident that not every change has benefitted or improved our community.
Report: California Sees Significant Increase in Female Directors After SB 826, but More Needed | JD Supra
A new report shows that the number of women on California corporate boards has increased 66.5% since 2018 after the state required corporations to have at least one to three female directors by 2021. Despite the significant progress, the total representation of women on California corporate boards remains at a minimal 24%.
Director Diversity and Derivative Lawsuits – Climate of Change | JD Supra
Diversity and inclusion in business has taken center stage in public discourse, and by-and-large, businesses have stated their commitment to diversity and inclusion, announcing various new initiatives to address racial inequality. Yet a wave of derivative and securities lawsuits, a recent California law signed by Governor Gavin Newsom (AB 979), and diversity legislation in other states have put a microscope on diversity at the board of director level.
Financial Crimes Enforcement Network, Treasury Department Affirm Regulatory Regime for Convertible Virtual Currencies | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
Financial Services Quarterly Report - First Quarter 2019: A U.S. Regulatory Patchwork Quilt: Cryptocurrency and Money Transmitter Licensing | JD Supra
According to its original design, Bitcoin was intended to reduce market participants’ need to rely on “financial institutions serving as trusted third parties to process electronic payments.”1 While Bitcoin and other cryptocurrencies based on blockchain technology have, at least in part, achieved this goal, the real-world use of cryptocurrencies has also created new opportunities for intermediaries to facilitate the practical use of cryptocurrencies by consumers, businesses and investors.
Discrimination and Algorithms in Financial Services: Unintended Consequences of AI | JD Supra
It’s troubling enough when facial recognition software couldn’t recognize Asian faces, the crime prediction algorithm targeted black neighborhoods, the job bank was more likely to show men highly paid executive jobs, and the criminal recidivism model had racial bias. But what about the day when the online lending platform uses big data to determine a person’s credit score and systematically rejects more loan applications from women or racial minorities than white men?
The Consumer Credit Market: The CFPB’s 2017 CARD Act Report
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Next Steps for the CFPB
Richard Cordray, the director of the U.S. Consumer Financial Protection Bureau (CFPB), resigned from this post at the close of business last Friday, November 24. In a statement to staff, he said that Leandra English, the CFPB’s chief of staff, had been named deputy director and would take over as acting director of the agency upon his exit.
CFPB Highlights Supervisory Findings Related to Credit Cards
Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra: Already signed up? Log in here By using the service, you signify your acceptance of JD Supra provides users with access to its legal industry publishing services (the "Service") through its website (the "Website") as well as through other sources.
CFPB’s First No-Action Letter: Supporting Innovation AND Supervision for Fair Lending
The Consumer Financial Protection Bureau (the “Bureau”) issued its first no-action letter (“NAL”) to Upstart Network, Inc. (“Upstart”), a marketplace lender that sought to clarify that its automated model for underwriting unsecured, non-revolving loans does not present a violation of the Equal Credit Opportunity Act (“ECOA”) and its implementing regulation, Regulation B.
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