Jarryd E. Anderson

1 month ago | lexology.com | Matthew Abbott |Jarryd E. Anderson |Jessica Carey |Andrew Fishman |Roberto González |Brad S. Karp | +1 more

For additional guidance on the Trump administration’s executive orders, visit our Regulatory/Administrative Tracker. To download a compendium of our recent analysis, click here.

Oct 29, 2024 | lexology.com | Jarryd E. Anderson |Jessica Carey |John Carlin |Roberto González |Brad S. Karp |Kannon K. Shanmugam | +1 more

On October 22, 2024, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) published a 594-page Notice of Final Rulemaking for its “Personal Financial Data Rights” rule, commonly known as the “Open Banking” rule, which will require covered entities—generally, providers of checking and prepaid accounts, credit cards, digital wallets, and other payment facilitators—to provide consumers and consumer-authorized third parties with access to consumers’ financial data free of charge.[1]...

Jun 10, 2024 | lexology.com | Jarryd E. Anderson |Susanna M. Buergel |Jessica Carey |Roberto González |Brad S. Karp |Jeannie S. Rhee | +1 more

On June 3, 2024, the Consumer Financial Protection Bureau (“CFPB”) issued a novel and expansive rule requiring certain nonbank providers of consumer financial services to register specified information with the agency in a public registry.[1] The 486-page final rule (“Final Rule”), which is scheduled to take effect September 16, requires nonbank companies that have been subject to certain final public enforcement orders by federal, state, or local agencies involving consumer financial...

Feb 26, 2024 | lexology.com | Jarryd E. Anderson |Scott A. Barshay |Jessica Carey |Brad S. Karp |Robert Kindler |Anastasia V. Peterson | +3 more

I. Executive SummaryOn January 29, 2024, the Office of the Comptroller of the Currency (“OCC”) issued a notice of proposed rulemaking (the “NPR”)[1] to update its current rules for business combinations involving national banks and federal savings associations, including a policy statement that describes the standards for the OCC’s review of business combinations under the Bank Merger Act (“BMA”) (the “Policy Statement”).

Jan 29, 2024 | lexology.com | Jarryd E. Anderson |H. Christopher Boehning |Susanna M. Buergel |Jessica Carey |Michael E. Gertzman |Roberto González | +3 more

Introduction On January 22, 2024, the New York State Department of Financial Services (“NYDFS”) issued final Guidance (the “Guidance”) for most institutions holding a license from the NYDFS[1] (“Covered Institutions”) setting out NYDFS’s expectation that Covered Institutions engage in rigorous character and fitness assessments of directors, senior officers and managers, both at onboarding and on an ongoing basis.[2] The Guidance reflects an ongoing effort by policymakers and regulators to...