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Obrea Poindexter Morrison & Foerster LLP

Results 1 to 5 of 88



CFPB uses novel interpretation, increases compliance burden for gift card issuers through its first preemption determination *

USA - April 23 2013
On April 19, 2013, the Consumer Financial Protection Bureau ("CFPB") announced it was making a determination to preempt a provision of Tennessee…

Co-authors: Leonard Chanin, Matthew W. Janiga, Richard Fischer.


Financial services report, Spring 2013 *

USA - March 12 2013
Despite numerous predictions of quick and easy passage, Congress finally passed and President Obama signed into law an amendment to the Federal…

Co-authors: Dwight Smith, Leonard Chanin, Andrew M. Smith, Richard Fischer, Charles M. Horn.


Financial Services Report, Winter 2012 *

USA - December 10 2012
On October 1, 2012, the CFPB brought its third major enforcement action against three American Express subsidiaries (“American Express”), requiring American Express to return $85 million to customers and pay approximately $14 million to the CFPB’s civil money penalty fund, with another $14 million in penalties to other regulators.

Co-authors: Leonard Chanin, Andrew M. Smith, Jim McCabe, Richard Fischer, Sean Ruff.


CFPB proposed amendments to Reg. Z ability-to-pay requirements *

USA - October 19 2012
On October 17, 2012, the Consumer Financial Protection Bureau (“CFPB”) issued a proposed rule (“Proposed Rule”) to amend the Truth in Lending Act’s (“TILA”) ability-to-pay requirements, as added by the Credit Card Accountability Responsibility and Disclosure Act of 2009 (“CARD Act”) and implemented by Regulation Z.

Co-authors: Oliver Ireland, Richard Fischer.


Summary of CFPB notice of intent for gift card preemption determinations *

USA - August 24 2012
On August 21, 2012, the Consumer Financial Protection Bureau (“CFPB”) published a notice of intent to make a preemption determination on whether provisions of abandoned property laws in Maine and Tennessee relating to gift cards should be preempted by the federal Electronic Fund Transfer Act (“EFTA”), as implemented by Regulation E (“Notice”).

Co-authors: Matthew W. Janiga, Richard Fischer, Sean Ruff.


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