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
Medical cannabis has arrived in Mississippi. What does that mean for Mississippi banks? The implications of this development are enormous for the financial services industry in Mississippi, as each institution will soon have to determine whether it will knowingly bank the proceeds of the state’s newest industry and, if not, how to ensure that it
For the first time in more than 20 years, FEMA has announced plans to make changes to its Standard Flood Insurance Policy (SFIP). Under the proposal, FEMA would introduce a new Homeowner Flood Form, to be published at 44 C.F.R. 61 appendix A(4), that would provide flood coverage for one-to-four residential properties. FEMA has
Congress has reauthorized the National Flood Insurance Program (NFIP) through February 18, 2022. Prior to this most recent temporary reauthorization, the NFIP had been set to expire on December 3, 2021. Since 2017, there have been 18 temporary reauthorizations as more comprehensive and permanent legislative solutions to the program have failed to gain traction in
On Tuesday, November 16, 2021, the Consumer Financial Protection Bureau (“CFPB”) issued a request for information seeking input on rules implementing the Home Mortgage Disclosure Act (“HMDA”), to evaluate whether the rules currently meet HMDA’s stated goals. HMDA, originally enacted in 1975, requires qualifying lenders to collect, report, and disclose data about originations and purchases
After the Consumer Financial Protection Bureau (CFPB) issued their Notice of Proposed Rulemaking (NPRM) related to Dodd-Frank 1071, Rohit Chopra, the new CFPB director, expressed his concern regarding the regulatory burden that the proposed rule would have on small banks. Director Chopra stated that he hoped the CFPB could move towards bright-lined rules that are
The Second Circuit last week in United States v. Halkbank significantly limited the immunity granted under the Foreign
Sovereign Immunities Act (FSIA) by giving a broad interpretation to the act’s “commercial activity” exception. Entities that could otherwise claim FSIA immunity should be aware that the commercial activity exception is likely to present a significant obstacle
The SAFE Banking Act passed in the U.S. House of Representatives for the fifth time on September 23, 2021. This
landmark legislation would pave the way for more financial institutions to serve the state-legal cannabis industry by removing some of the attendant legal and regulatory risks, as we have previously explained.
In a tactical