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HTMLMilitary Lending Act: Let's Just Throw that Baby Out with the Bath Water
Maurice L. Shevin; Sirote & Permutt, P.C.;
Legal Alert/Article
March 23, 2015, previously published on January 13, 2015
The CFPB has joined in the fray over the expansion of the Military Lending Act's application to traditional installment lending.

 

HTMLNevada Supreme Court Clarifies That 'Consideration Paid' by Successor Note-Holders Can Limit Recovery in Deficiency Actions
Leslie S. Godfrey, Kara B. Hendricks, Michael R. Hogue; Greenberg Traurig, LLP;
Legal Alert/Article
March 19, 2015, previously published on March 10, 2015
In late 2013, the Nevada Supreme Court issued a 5-2 decision in Sandpointe Apartments v. Eighth Judicial Dist. Ct. which found that 2011 amendments modifying Nevada’s anti-deficiency protections created limitations on the amount a note-purchaser could recover as part of a deficiency judgment....

 

HTMLFederal Law Friday: When Denying Credit (Adverse) Actions Speak Louder Than Words
Samuel D. Friedman; Sirote & Permutt, P.C.;
Legal Alert/Article
March 19, 2015, previously published on December 19, 2014
In our Federal Law Friday series, each week we review a different Federal law that should be covered by a finance company's policies, procedures and compliance management system. This week, we review the Adverse Action Rules.

 

HTMLNo One Likes a Complainer, Except Maybe the CFPB
Samuel D. Friedman; Sirote & Permutt, P.C.;
Legal Alert/Article
March 19, 2015, previously published on December 9, 2014
As we have discussed in a previous post, a successful compliance management system needs to include four components: (1) board and management oversight, (2) a written compliance program, (3) response to complaints, and (4) a compliance audit. Today, we review component three—the importance of...

 

HTMLWhat's the CFPB Cooking for the Holidays?
Samuel D. Friedman; Sirote & Permutt, P.C.;
Legal Alert/Article
March 19, 2015, previously published on December 2, 2014
It truly is the most wonderful time of the year in the South. The air is crisp. The football is good. And, it seems like there is always something cooking. Washington is no different (other than maybe the good football part).

 

HTMLLet's Take a Quick Look at the CFPB—by the Numbers
Maurice L. Shevin; Sirote & Permutt, P.C.;
Legal Alert/Article
March 19, 2015, previously published on December 16, 2014
Each year, the CFPB publishes an “annual performance report” to let the taxpayers know what's going on in Washington. As far as federal agencies go, the CFPB seems to have figured out how to make money for Uncle Sam! Let's see how.

 

HTMLFederal Law Friday: You Better Safeguard My Identity From The Bad Guys!
Maurice L. Shevin; Sirote & Permutt, P.C.;
Legal Alert/Article
March 19, 2015, previously published on December 5, 2014
In our Federal Law Friday series, each week we review a different Federal law or regulation that should be covered by a finance company’s policies, procedures and compliance management system. This week, we review the Red Flags Rule.

 

HTMLBrazil’s CADE Executes Cooperation Agreement with IDB and World Bank
Eduardo Molan Gaban; Mayer Brown LLP;
Legal Alert/Article
March 18, 2015, previously published on March 17, 2015
The Administrative Council for Economic Defense (“CADE”) has recently executed a “Memorandum of Understanding” with the World Bank Group, as well as a “Covenant for Cooperation and Sharing of Information” with the Inter-American Development Bank...

 

HTMLUnderstanding SwissLeaks: Considerations for Banks, Account Holders and Fiduciaries in Light of Possible Enforcement Action in India
Saionton Basu; Duane Morris;
Legal Alert/Article
March 18, 2015, previously published on March 13, 2015
Last month saw further disclosure of 1,195 account holders in HSBC Private Bank in Geneva, Switzerland, with Indian addresses. Whilst that by itself connotes no manner of wrongdoing, given the information now resides in the public domain, the following potential risks emerge for banks, account...

 

Adobe PDFJOBS Act - Increased Thresholds for Exchange Act Registration: SEC Proposes Rule Amendments to Implement JOBS Act Provisions That Increased Thresholds for Registration and Reporting Obligations
Robert Buckholz, Catherine M. Clarkin, Jay Clayton, Audra D. Cohen, H. Rodgin Cohen; Sullivan & Cromwell LLP;
Legal Alert/Article
March 18, 2015, previously published on December 23, 2014
On December 18, 2014, the SEC issued a release proposing amendments to various Exchange Act rules to reflect the new, higher thresholds for Exchange Act registration by all issuers, and for termination of registration and suspension of reporting by banks and bank holding companies, that were set...

 


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