Category Archive: Dodd-Frank Law

Paying Your Credit Card By Phone; What Are The Fees?

A compliance bulletin discussing fees charged to consumers to pay-by-phone (“Bulletin dated July 31, 2017”) was published by  The Consumer Financial Protection Bureau (the “CFPB”),    The CFPB stated that these fees may amount to unfair, deceptive or abusive acts or practices known as “UDAAP”.  UDAAP practices are prohibited by federal law under 12 USC 5531 […]

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CFPB And Commercial Credit

Does the Consumer Financial Protection Bureau (“CFPB”)  have jurisdiction over “commercial credit”? Rep. Emanuel Cleaver II,  raised certain concerns  in a recent letter to the CFPB (the “Cleaver Letter”) , which can help us answer this question.  As we know, fintech lending is based upon the use of algorithms to determine whether to provide commercial […]

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Trump Administration Regulatory Freeze. What Is The Effect On The CFPB

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 […]

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AlexsonLaw Services. How We Help You To Reduce Costs And Legal Risk

My firm specializes in transactions, regulations, strategic alliances and mixed collateral loan transactions in the real estate and financial services industries. We are positioned in a unique space in that my many years in big firm law and my expertise in complex mixed collateral transactions, mergers and acquisitions, private funds, fintech  and bank regulation allow […]

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Commercial Real Estate And Dodd-Frank Risk Retention Rules

The Dodd-Frank statute also led to the adoption of Regulation 15G of the Securities and Exchange Act of 1934 (15 U.S.C.A. § 78o-11), which requires the sponsor in a CMBS securitization to retain a 5% stake in the credit risk of the underlying commercial real estate asset. The purported purpose of the regulations is to […]

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Dodd-Frank And Commercial Real Estate

What’s Next? Some experts in the financial services industry, believe that the new Trump administration may change or roll-back a portion of the Dodd-Frank legislation. Financial institutions, mortgage companies, securitization sponsors, etc.  must continue to treat  current regulatory requirements as applicable to the business.  It is important to differentiate the commitment to protection of consumers […]

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