On July 10, 2017, the Consumer Financial Protection Bureau (CFPB) issued a final rule prohibiting class action waivers in predispute arbitration clauses contained in covered consumer financial services agreements. The four primary provisions of the final rule are as follows: Under the final rule, a “predispute arbitration agreement” is defined as: “an agreement between a […]
Continue reading →There is some confusion in the marketplace with respect to new loan products and services in the banking industry. My definition of “FINTECH” is broad and encompasses computer programs, applications and other technology used to provide banking and financial services. Perhaps you have noticed that many retail bank services have been streamlined through on-line payment, […]
Continue reading →The Trump Administration circulated a memorandum on January 20, 2017 (the “January 2017 Memo”) to the heads of executive departments and agencies, initiating a regulatory review to be headed by the Director of the Office of Management and Budget (“OMB”). The January 2017 Memo states in relevant part, “[S]end no regulation to the Office of […]
Continue reading →We consult with marketplace lenders and community banks and other lenders to create a strategic partnership to meet both parties’ business goals. It may be more cost effective to partner with a FinTech provider or marketplace lender than to create a new platform. We offer a value-based consulting product to analyze goals, prepare a strategic […]
Continue reading →The Supreme Court of the United States recently released a 6-2 opinion regarding the sufficiency of a claim based upon alleged statutory violations (Spokeo, Inc. v. Robins, No. 13-1339, decided May 16, 2016). The complainant, Robins, accused Spokeo, Inc., allegedly a consumer reporting agency, of violating specific portions of the Fair Credit Reporting Act of […]
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