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Bureau Proposes to Simplify “Disclosure Sandbox” Policy
On September 10, 2018, the Bureau of Consumer Financial Protection issued proposed revisions to its “Disclosure Sandbox” policy statement, which is formally titled, “Policy to Encourage Trial Disclosure Programs” (Policy). 83 FR 45574.
Closing Disclosure for Seller
Question: When is a creditor responsible for providing a Closing Disclosure (CD) to the seller?
FDIC Proposes Rule Reciprocal Deposits’ Treatment
On September 26, 2018, the FDIC published a proposal to implement Section 202 of the Economic Growth, Regulatory Relief and Consumer Protection Act (Relief Act). 83 FR 48562.
Agencies Disclaim Guidance Documents’ Legal Force
The federal banking agencies issued a statement on September 11, 2018 disclaiming that their supervisory guidance has the force of law. The statement includes the following: “Unlike a law or regulation, supervisory guidance does not have the force and effect of law, and the agencies do not take enforcement actions based on supervisory guidance.”
NCUA Proposes Increase to Appraisal Threshold for Non-Residential Real Estate Loans and More
On September 20, 2018, the NCUA issued a proposal to amend its real estate appraisal regulations (12 CFR Part 722) that apply to certain real property-secured transactions. 83 FR 49857. The goal is to provide federal credit unions with some regulatory relief.
California Supreme Court: Employees Must be Paid for Off-the-Clock Work
In answering a question for the Ninth Circuit, the California Supreme Court has ruled that employers must pay hourly employees for all work performed whether on or off the clock. Troester v. Starbucks Corp., 5 Cal. 5th 829 (Cal. 2018).
Table of Contents
Consumer Finance
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Bureau Proposes to Simplify “Disclosure Sandbox” Policy
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Sometimes False Advertising is Obvious
Consumer Finance Q&A
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Closing Disclosure for Seller
Banking Operations & FinTech
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FDIC Proposes Rule Reciprocal Deposits’ Treatment
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OCC Updates Deposit-Related Credit Booklet
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NACHA Enhances Same-Day ACH Processing
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FTC Mails $10 Million in Monetary Relief to NetSpend Customers
Corporate Governance
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Agencies Disclaim Guidance Documents’ Legal Force
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OCC Proposes to Extend National Bank Powers to Eligible Savings Associations
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Agencies Extend Comment Period on Proposed Volcker Rule Amendments
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Immediate Relief for Small Bank Holding Companies
Credit Unions
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NCUA Proposes Increase to Appraisal Threshold for Non-Residential Real Estate Loans and More
Employment
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California Supreme Court: Employees Must be Paid for Off-the-Clock Work
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DOL Opinion Letters: No-fault Attendance Policies and Organ Donation
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ACA, FCRA and FMLA Forms Updated
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