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Caroline Waters is an associate in the Banking and Financial Services Practice Group. Caroline graduated (summa cum laude) from the University of Tennessee College of Law and was named to the Order of the Coif. While in law school, she was the acquisitions editor for the Tennessee Law Review, where she received the Silver Pen Award for her student note and the editing award for her contributions to the law review. Caroline also served as a judicial extern for the Hon. Thomas A. Varlan of the United States District Court for the Eastern District of Tennessee.

Prior to law school, Caroline earned a B.S.B.A. (summa cum laude) in Finance from Auburn University.

On May 5, 2022, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (collectively the agencies) issued a joint notice of proposed rulemaking (the Proposed CRA Rule) that proposes changes to the way the agencies evaluate a bank’s performance under the

On Monday, the CFPB issued a press release announcing that it will start using its authority to examine non-bank financial services institutions that the CFPB has “reasonable cause to determine pose risks to consumers.” In addition, the CFPB has released a procedural rule designed to “increase transparency of the risk-determination process” by subjecting the results

Beginning next year, New Mexico will join a handful of other states (including, among others, California, Illinois, and Colorado) setting stringent interest rate caps on consumer loans. House Bill 132, which Gov. Michelle Lujan Grisham signed on March 1, 2022, will slash the annual percentage rate (APR) applicable to loans made under New Mexico’s

Servicers That Fail to Prepare, Prepare to Fail, Warns NY AGIn a December 13, 2021 letter to servicers, New York Attorney General Letitia James reminded servicers of their continuing obligations to assist New Yorkers amidst the pandemic and warned of enforcement actions against servicers that fail to do so. According to Attorney General James, “lack of preparedness is no excuse.” Instead, the Office of the

New York DFS Proposes Regulation to Implement TILA-Like Requirements on Small Business LoansOn September 21, 2021, New York’s Department of Financial Services (DFS) announced proposed regulations that clarify the small business Truth in Lending disclosure requirements that go into effect on January 1, 2022. The proposed regulations come just in time as non-banks and fintechs are attempting to prepare to comply with the commercial financing law with