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Regulation & Compliance

Regulatory advice and compliance support for financial services companies

We advise banks, fintechs, mortgage companies and others on regulatory compliance across the full spectrum of consumer protection and prudential requirements. Our regulatory practice covers consumer compliance (TILA, RESPA, UDAP/UDAAP, FCRA, HMDA, fair lending), safety and soundness issues, payments rules, and regulatory change management. We help clients understand the impact of new regulations, build compliance programs, and maintain comprehensive regulatory inventories.

Services provided by the Regulation & Compliance practice include:

Capital Analysis: We assess treatment of assets, instruments, and transactions under bank or GSE capital rules.
Consumer Compliance: We assist clients with compliance matters on a variety of federal banking and consumer financial services laws including TILA, RESPA, HMDA, FCRA, CRA, privacy, fair lending, compliance management, and UDAP/UDAAP.
Impact Analysis: We help clients understand the impact of existing and proposed laws and regulations on new or existing products and services.
Payments Advice: We advise clients on payments regulation, market structure, and policy, including payment system access, faster payments, and innovative payment products.
Regulatory Inventory: We build and maintain comprehensive and special-purpose inventories of regulatory content and obligations.
Safety and Soundness: We provide clients with support on safety and soundness issues including Regulation W (transactions with affiliates), Regulation O (insider lending), capital adequacy, and Regulation Y (holding companies).
Bank Powers & Permissible Activities Bank Secrecy Act Capital, Liquidity & Prudential Standards CRA Compliance Management Confidential Supervisory Information Consumer Financial Protection EFTA ECOA FCRA HMDA Insider Lending (Regulation O) Payment Systems CFPA 1033 Preemption & Rate Exportation Privacy & Data Protection RESPA Third-Party Risk Management Transactions with Affiliates (Regulation W) TILA UDAAP/UDAP

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Analysis

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Analysis

Recent Executive Orders Regarding Financial Services

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On Tuesday, May 19th, President Trump issued two Executive Orders regarding financial services. The first, Integrating Financial Technology Innovation into Regulatory Frameworks, addresses the role of fintechs in the financial system, including supporting bank-fintech partnerships, charters, and access to Federal Reserve payment systems. The second, Restoring Integrity to America’s Financial System, covers banking products and services provided to immigrants and related BSA/AML and ability-to-repay requirements. Neither will result in immediate changes. Rather, the EOs direct the federal...

Analysis

CFPB's Final Rule on Small Business Lending Data (Section 1071)

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Insight

Unusual dissension in Fed vote on Reg W exemption

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The drama around yesterday's Fed decision to grant Morgan Stanley a 23A exemption makes the exemption a tempting target for criticism. But a minor factual error in Governor Bowman's statement defending the decision reveals critical context that puts the decision in perspective. In case you missed it, the Fed Board voted 4-3 to approve an exemption letting Morgan Stanley move a significant trading operation from its European non-bank subsidiary to its US FDIC-insured bank. Such a transaction would usually be prohibited by the restrictions on bank transactions with their affiliates in the...

Analysis

CFPB Advisory Opinion on Earned Wage Access Under Regulation Z

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Analysis

Key Implications if the CFPB Is No Longer Operational

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