Archive

MANAGING SERVICE PROVIDER RISKS

On April 13th the Consumer Financial Protection Bureau (CFPB) released a bulletin clarifying that financial institutions may be held responsible for the actions of the companies with which they contract. The other federal bank regulatory agencies have held the same position for years. Banks and nonbanks contract with service providers for a number of reasons. They may use service providers to develop and market additional products or services or to provide expertise. Banks may also […]

CFPB – A CONTINUATION OF THE SAME OLD STORY

It is not that often that a new federal financial institution regulatory agency is created, but when it happens one can only hope for something better than what existed before. But the Consumer Financial Protection Bureau (CFPB) continues to disappoint. The latest disappointment is relatively minor. In their regulatory agenda published last fall the CFPB stated that final rules revising Regulation Z provisions dealing with the borrower’s ability to repay would be published in April […]