The SEC’s Division of Examinations last week announced its 2023 “examination priorities.” The division’s annual announcement of priorities provides valuable insight into the categories of registrants most likely to be the subject of an SEC examination and the issues most likely to be a focus of those examinations. In determining its priorities, the division employs
As we all hit the grocery store for that forgotten cranberry sauce and send a few last urgent work emails, we hope everyone is able to be with friends and family this Thanksgiving. Here at Bradley, we are counting our blessings and looking back at another remarkable year. We are thankful for being able to
On July 27, 2022, the Consumer Financial Protection Bureau (CFPB) and the United States Department of Justice (DOJ) filed a complaint in the United States District Court for the Eastern District of Pennsylvania against Trident Mortgage Company LP for alleged discrimination against minority families in the greater Philadelphia area.
According to the CFPB’s press release
In 2018, California became the first state to pass a commercial finance disclosure law (CDL) requiring certain commercial finance companies to make consumer-style disclosures to financing recipients. The CDL was the catalyst for the passage of similar laws in Utah, Virginia, and New York, and the introduction of commercial disclosure legislation in many other states
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
West Virginia recently became the second state to enact financial regulations designed to ward off efforts to deny fossil fuel companies access to banking services – but it looks like it may not be the last. On March 30, 2022, West Virginia Senate Bill 62 became law, requiring that all branches of state government cease
Until last month, government enforcement and regulatory scrutiny of fraud and other misconduct relating to COVID-19 relief programs was generally limited to end recipients of the relief. These efforts have mostly been directed to fraud in connection with the Paycheck Protection Program (PPP), a nearly $1 trillion business loan program administered by the Small Business
On March 15, 2022, the Consolidated Appropriations Act, 2022 – which included the Adjustable Interest Rate (LIBOR) Act – was signed into law. The LIBOR Act is meant to address concerns with ceasing the use of LIBOR by creating a uniform process for replacing LIBOR in those existing contracts that do not provide for the
On February 16, 2022, legislators Blaine Luetkemeyer, French Hill, and Roger Williams submitted a letter to Consumer Financial Protection Bureau (CFPB) Director Rohit Chopra raising concerns regarding the Bureau’s Dodd Frank Act Section 1071 rulemaking.
As we have discussed, the CFPB issued its Section 1071 Notice of Proposed Rulemaking (NPRM) on September 1, 2021.
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