Bank Law Monitor

Bank Law Monitor

A Legal Blog for the Financial Services Industry

Tag Archives: UDAAP

OCC Invites Fintech Companies to Become Special Purpose National Banks

Posted in Banking, Banking Technology
Last week, the Office of the Comptroller of the Currency (OCC) officially opened its doors to financial technology companies and encouraged them to apply to become “special purpose” national banks. The premise is simple—become a national bank, abide by the OCC’s rules and regulations, and so-called “fintech” companies can avoid much of the thicket of… Continue Reading

CFPB Fines PayPal $25 Million for Violations of UDAAP

Posted in CFPB, Regulatory Developments, UDAAP
On May 19, 2015, the CFPB announced that it was filing a complaint and proposed consent order in federal court against PayPal, Inc., based on allegations that PayPal Credit (fka “Bill Me Later”), had violated the prohibition against unfair, deceptive, abusive acts and practices (UDAAP).  This filing is noteworthy for two reasons. First, it was… Continue Reading

CFPB Pursuing Mortgage Servicers with UDAAP

Posted in CFPB, Mortgage Servicing, Regulatory Developments, UDAAP
On September 29, 2014, the CFPB took action against Flagstar Bank for violating the CFPB’s new mortgage servicing rules by “illegally blocking borrowers’ attempts to save their homes.” The CFPB focused on the Flagstar’s actions from 2011 to present and found that Flagstar failed to devote sufficient resources to administering loss mitigation programs for distressed… Continue Reading