Federal Issues

CFPB Orders Credit Union to Pay $28.5 Million Over Debt Collection Practices. On October 11, the CFPB issued a consent order to a Virginia-based federal credit union to resolve allegations that its debt collection activities were unfair and deceptive in violation of the Dodd-Frank Wall Street Reform and Consumer Protection Act. According to the CFPB’s consent order, the credit union failed to implement adequate compliance controls and employee training on debt collection communications. The credit union’s actions involved employees who sent letters to “hundreds of thousands” of consumers containing various misrepresentations regarding the handling of consumer debt. The consent order alleged that these debt collection letters falsely threatened legal action, wage garnishment, and contacting servicemembers’ commanding officers for failure to remit payments. Read more here.

CFPB Releases Updated TRID Compliance Guide. On October 12, the CFPB issued an updated version of its small entity compliance guide on the Know Before You Owe TILA-RESPA Integrated Disclosure (TRID) Rule. The updated TRID compliance guide incorporates guidance from CFPB webinars on various topics, including (i) record retention; (ii) Loan Estimate and Closing Disclosure requirements, including format and delivery; (iii) good faith standards and determinations; (iv) disclosures related to seller-paid costs; and (v) construction loans. The newly released TRID compliance guide replaces the CFPB’s July 2015 guide. The CFPB also issued a separate revised guide for completing the Loan Estimate and Disclosure forms.

CFPB Names John Coleman Deputy General Counsel for Litigation and Oversight. On October 13, the CFPB announced various senior leadership changes. John Coleman will now serve as the CFPB’s Deputy General Counsel for Litigation and Oversight in the Legal Division. Coleman joined the CFPB in November 2010 and has since served as Assistant General Counsel for Litigation and as Senior Litigation Counsel. Additional leadership changes include Stacy Canan serving as Assistant Director for the Office for Older Americans, and Sonya White serving as Deputy General Counsel for General Law and Ethics in the Legal Division.

Federal Reserve Board Member Recognizes Blockchain Technology’s Potential; Warns of Associated Risks. On October 7, at the Institute of International Finance Annual Meeting Panel on Blockchain, Federal Reserve Board member Lael Brainard delivered a speech titled “Distributed Ledger Technology: Implications for Payments, Clearing, and Settlement.” Brainard acknowledged blockchain technology as possibly the “most significant development in many years in payments, clearing, and settlement” and outlined its potential “to transform the way financial market participants transfer, store, and maintain ownership records of digitized assets.” Brainard highlighted payment technology changes as a particular regulatory focus and emphasized the Federal Reserve’s “responsibilities for promoting the safety and efficiency of the payments and settlements systems; supervising financial institutions engaged in payments, clearing and settlement; and safeguarding financial stability.” Read more here.

OFAC Publishes Fact Sheet and FAQ Related to Termination of Burma Sanctions Program; Updates SDN List. On October 7, OFAC published a Fact Sheet and Frequently Asked Question (FAQ) number 481 regarding the implementation of the President’s Executive Order entitled “Termination of Emergency with Respect to the Actions and Policies of the Government of Burma.” OFAC’s fact sheet explains that all OFAC-administered restrictions and authorizations under the Burma sanctions program pertaining to banking with Burma, including 2012 and 2013 OFAC general licenses that authorized certain correspondent account activity with Burmese banks, are terminated pursuant to the Executive Order. FAQ 481 clarifies that “[p]ending OFAC enforcement matters will proceed irrespective of the termination of OFAC-administered sanctions on Burma, and OFAC will continue to review apparent violations of the [Burmese Sanctions Regulations], whether [such violations] came to the agency’s attention before or after the Burma sanctions program was terminated.” In connection with terminating the Burma-related sanctions program, OFAC made several deletions to its SDN List.

OFAC Updates Iran-Related FAQs. On October 7, OFAC updated its Frequently Asked Questions (FAQs) relating to the Listing of Certain U.S. Sanctions under the Joint Comprehensive Plan of Action (JCPOA). In addition to adding three FAQs related to due diligence (see M.10 through M.12), OFAC amended two FAQs (C.7 and C.15) regarding Financial and Banking Measures and one FAQ (K.19) related to Foreign Entities Owned or Controlled by U.S. Persons. FAQ M.10 clarifies that while “[i]t is not necessarily sanctionable for a non-U.S. person to engage in transactions with an entity that is not on the SDN List but that is minority owned, or that is controlled in whole or in part, by an Iranian or Iran-related person on the SDN List,” it is recommended that persons engaging in such transactions exercise caution to ensure that they do not involve Iranian or Iran-related persons on the SDN List. FAQs M.11 and M.12, respectively, address (i) due diligence expectations related to the screening of potential Iranian counterparties; and (ii) the circumstances under which OFAC expects a non-U.S. financial institution to repeat the due diligence their customers have already performed on an Iranian customer.

Treasury and Federal Reserve Support G-7 Elements of Cybersecurity for the Financial Sector. On October 11, the U.S. Department of the Treasury announced that the Group of Seven (G-7) countries – comprised of the United States, Canada, France, Germany, Italy, Japan, and the United Kingdom – issued fundamental elements to “help address cyber risks facing the financial sector from both entity-specific and system-wide perspectives.” In Fundamental Elements of Cybersecurity for the Financial Sector, G-7 outlines eight elements for private and public entities within the financial sector to use as “building blocks” for confronting cyber-related issues, the first of which is to establish and implement tailored cybersecurity strategies and operational frameworks that should be tailored to an entity’s nature, size, complexity, risk profile, and culture. Read more here.

OCC Releases Bulletin on Revised Examination Procedures for the Military Lending Act. On October 7, following the Federal Reserve’s and the CFPB’s leads, the OCC released Bulletin 2016-33 advising financial institutions of updated interagency examination procedures for compliance with the Department of Defense’s (DoD) Military Lending Act (MLA) July 2015 final rule. As previously summarized in BuckleySandler’s Special Alert, the DoD issued an interpretive rule regarding the amendments to the regulations implementing the MLA on August 26, 2016. The 2015 final rule went into effect for consumer credit products other than credit cards on October 3, 2016. The requirements will take effect for credit card accounts one year later, on October 3, 2017. The OCC plans to include the updated interagency examination procedures in the Comptroller’s Handbook.

State Issues

NYDFS Issues New Guidance on Banks’ Incentive Compensation Arrangements. On October 11, the New York Department of Financial Services (NYDFS) issued new guidance regarding incentive compensation arrangements, advising “all regulated banking institutions that no incentive compensation may be tied to employee performance indicators, such as the number of accounts opened, or the number of products sold per customer, without effective risk management, oversight and control.” At a minimum, the guidance requires that a bank’s incentive compensation arrangement address the following principles: (i) balance between risks and rewards; (ii) effective controls and risk management; and (iii) effective corporate governance. NYDFS stated that a bank’s lack of compliance with the guidance will be reflected in its regulatory examination rating and may result in additional regulatory action. Read more here.

Miscellany

ABA and Regional Members Lend Perspective on CFPB’s Proposed Rule on Payday, Title, and Certain Other Installment Loans. On October 7, the American Bankers Association (ABA) sent a comment letter to the CFPB regarding the agency’s proposed rule on payday, title, and certain other installment loans. Describing the proposal as “exceedingly and unnecessarily complex,” the ABA argues that the proposed rule imposes significant restrictions on the small-dollar credit industry by limiting financial institutions’ ability to make small-dollar loans to consumers in need of such credit. In addition to asserting that the proposal reflects an over-reach of the CFPB’s statutory authority to regulate unfair, deceptive or abusive acts or practices, the comment letter contends that, if adopted, the proposed rule would, among other things, (i) “stifle innovation in consumer lending, reduce consumer choice, and directly harm the very borrowers [it] was intended to protect”; (ii) impose an unlawful cap on interest rates; (iii) regulate insurance, thereby violating the Dodd-Frank Act; and (iv) levy substantial costs on consumers and lenders. Read more here.

Banking

OFAC Publishes Fact Sheet and FAQ Related to Termination of Burma Sanctions Program; Updates SDN List. On October 7, OFAC published a Fact Sheet and Frequently Asked Question (FAQ) number 481 regarding the implementation of the President’s Executive Order entitled “Termination of Emergency with Respect to the Actions and Policies of the Government of Burma.” OFAC’s fact sheet explains that all OFAC-administered restrictions and authorizations under the Burma sanctions program pertaining to banking with Burma, including 2012 and 2013 OFAC general licenses that authorized certain correspondent account activity with Burmese banks, are terminated pursuant to the Executive Order. FAQ 481 clarifies that “[p]ending OFAC enforcement matters will proceed irrespective of the termination of OFAC-administered sanctions on Burma, and OFAC will continue to review apparent violations of the [Burmese Sanctions Regulations], whether [such violations] came to the agency’s attention before or after the Burma sanctions program was terminated.” In connection with terminating the Burma-related sanctions program, OFAC made several deletions to its SDN List.

OFAC Updates Iran-Related FAQs. On October 7, OFAC updated its Frequently Asked Questions (FAQs) relating to the Listing of Certain U.S. Sanctions under the Joint Comprehensive Plan of Action (JCPOA). In addition to adding three FAQs related to due diligence (see M.10 through M.12), OFAC amended two FAQs (C.7 and C.15) regarding Financial and Banking Measures and one FAQ (K.19) related to Foreign Entities Owned or Controlled by U.S. Persons. FAQ M.10 clarifies that while “[i]t is not necessarily sanctionable for a non-U.S. person to engage in transactions with an entity that is not on the SDN List but that is minority owned, or that is controlled in whole or in part, by an Iranian or Iran-related person on the SDN List,” it is recommended that persons engaging in such transactions exercise caution to ensure that they do not involve Iranian or Iran-related persons on the SDN List. FAQs M.11 and M.12, respectively, address (i) due diligence expectations related to the screening of potential Iranian counterparties; and (ii) the circumstances under which OFAC expects a non-U.S. financial institution to repeat the due diligence their customers have already performed on an Iranian customer.

OCC Releases Bulletin on Revised Examination Procedures for the Military Lending Act. On October 7, following the Federal Reserve’s and the CFPB’s leads, the OCC released Bulletin 2016-33 advising financial institutions of updated interagency examination procedures for compliance with the Department of Defense’s (DoD) Military Lending Act (MLA) July 2015 final rule. As previously summarized in BuckleySandler’s Special Alert, the DoD issued an interpretive rule regarding the amendments to the regulations implementing the MLA on August 26, 2016. The 2015 final rule went into effect for consumer credit products other than credit cards on October 3, 2016. The requirements will take effect for credit card accounts one year later, on October 3, 2017. The OCC plans to include the updated interagency examination procedures in the Comptroller’s Handbook.

NYDFS Issues New Guidance on Banks’ Incentive Compensation Arrangements. On October 11, the New York Department of Financial Services (NYDFS) issued new guidance regarding incentive compensation arrangements, advising “all regulated banking institutions that no incentive compensation may be tied to employee performance indicators, such as the number of accounts opened, or the number of products sold per customer, without effective risk management, oversight and control.” At a minimum, the guidance requires that a bank’s incentive compensation arrangement address the following principles: (i) balance between risks and rewards; (ii) effective controls and risk management; and (iii) effective corporate governance. NYDFS stated that a bank’s lack of compliance with the guidance will be reflected in its regulatory examination rating and may result in additional regulatory action. Read more here.

ABA and Regional Members Lend Perspective on CFPB’s Proposed Rule on Payday, Title, and Certain Other Installment Loans. On October 7, the American Bankers Association (ABA) sent a comment letter to the CFPB regarding the agency’s proposed rule on payday, title, and certain other installment loans. Describing the proposal as “exceedingly and unnecessarily complex,” the ABA argues that the proposed rule imposes significant restrictions on the small-dollar credit industry by limiting financial institutions’ ability to make small-dollar loans to consumers in need of such credit. In addition to asserting that the proposal reflects an over-reach of the CFPB’s statutory authority to regulate unfair, deceptive or abusive acts or practices, the comment letter contends that, if adopted, the proposed rule would, among other things, (i) “stifle innovation in consumer lending, reduce consumer choice, and directly harm the very borrowers [it] was intended to protect”; (ii) impose an unlawful cap on interest rates; (iii) regulate insurance, thereby violating the Dodd-Frank Act; and (iv) levy substantial costs on consumers and lenders. Read more here.

Consumer Finance

CFPB Orders Credit Union to Pay $28.5 Million Over Debt Collection Practices. On October 11, the CFPB issued a consent order to a Virginia-based federal credit union to resolve allegations that its debt collection activities were unfair and deceptive in violation of the Dodd-Frank Wall Street Reform and Consumer Protection Act. According to the CFPB’s consent order, the credit union failed to implement adequate compliance controls and employee training on debt collection communications. The credit union’s actions involved employees who sent letters to “hundreds of thousands” of consumers containing various misrepresentations regarding the handling of consumer debt. The consent order alleged that these debt collection letters falsely threatened legal action, wage garnishment, and contacting servicemembers’ commanding officers for failure to remit payments. Read more here.

CFPB Releases Updated TRID Compliance Guide. On October 12, the CFPB issued an updated version of its small entity compliance guide on the Know Before You Owe TILA-RESPA Integrated Disclosure (TRID) Rule. The updated TRID compliance guide incorporates guidance from CFPB webinars on various topics, including (i) record retention; (ii) Loan Estimate and Closing Disclosure requirements, including format and delivery; (iii) good faith standards and determinations; (iv) disclosures related to seller-paid costs; and (v) construction loans. The newly released TRID compliance guide replaces the CFPB’s July 2015 guide. The CFPB also issued a separate revised guide for completing the Loan Estimate and Disclosure forms.

CFPB Names John Coleman Deputy General Counsel for Litigation and Oversight. On October 13, the CFPB announced various senior leadership changes. John Coleman will now serve as the CFPB’s Deputy General Counsel for Litigation and Oversight in the Legal Division. Coleman joined the CFPB in November 2010 and has since served as Assistant General Counsel for Litigation and as Senior Litigation Counsel. Additional leadership changes include Stacy Canan serving as Assistant Director for the Office for Older Americans, and Sonya White serving as Deputy General Counsel for General Law and Ethics in the Legal Division.

OCC Releases Bulletin on Revised Examination Procedures for the Military Lending Act. On October 7, following the Federal Reserve’s and the CFPB’s leads, the OCC released Bulletin 2016-33 advising financial institutions of updated interagency examination procedures for compliance with the Department of Defense’s (DoD) Military Lending Act (MLA) July 2015 final rule. As previously summarized in BuckleySandler’s Special Alert, the DoD issued an interpretive rule regarding the amendments to the regulations implementing the MLA on August 26, 2016. The 2015 final rule went into effect for consumer credit products other than credit cards on October 3, 2016. The requirements will take effect for credit card accounts one year later, on October 3, 2017. The OCC plans to include the updated interagency examination procedures in the Comptroller’s Handbook.

ABA and Regional Members Lend Perspective on CFPB’s Proposed Rule on Payday, Title, and Certain Other Installment Loans. On October 7, the American Bankers Association (ABA) sent a comment letter to the CFPB regarding the agency’s proposed rule on payday, title, and certain other installment loans. Describing the proposal as “exceedingly and unnecessarily complex,” the ABA argues that the proposed rule imposes significant restrictions on the small-dollar credit industry by limiting financial institutions’ ability to make small-dollar loans to consumers in need of such credit. In addition to asserting that the proposal reflects an over-reach of the CFPB’s statutory authority to regulate unfair, deceptive or abusive acts or practices, the comment letter contends that, if adopted, the proposed rule would, among other things, (i) “stifle innovation in consumer lending, reduce consumer choice, and directly harm the very borrowers [it] was intended to protect”; (ii) impose an unlawful cap on interest rates; (iii) regulate insurance, thereby violating the Dodd-Frank Act; and (iv) levy substantial costs on consumers and lenders. Read more here.

Data Risk / Privacy

Treasury and Federal Reserve Support G-7 Elements of Cybersecurity for the Financial Sector. On October 11, the U.S. Department of the Treasury announced that the Group of Seven (G-7) countries – comprised of the United States, Canada, France, Germany, Italy, Japan, and the United Kingdom – issued fundamental elements to “help address cyber risks facing the financial sector from both entity-specific and system-wide perspectives.” In Fundamental Elements of Cybersecurity for the Financial Sector, G-7 outlines eight elements for private and public entities within the financial sector to use as “building blocks” for confronting cyber-related issues, the first of which is to establish and implement tailored cybersecurity strategies and operational frameworks that should be tailored to an entity’s nature, size, complexity, risk profile, and culture. Read more here.

International

OFAC Publishes Fact Sheet and FAQ Related to Termination of Burma Sanctions Program; Updates SDN List. On October 7, OFAC published a Fact Sheet and Frequently Asked Question (FAQ) number 481 regarding the implementation of the President’s Executive Order entitled “Termination of Emergency with Respect to the Actions and Policies of the Government of Burma.” OFAC’s fact sheet explains that all OFAC-administered restrictions and authorizations under the Burma sanctions program pertaining to banking with Burma, including 2012 and 2013 OFAC general licenses that authorized certain correspondent account activity with Burmese banks, are terminated pursuant to the Executive Order. FAQ 481 clarifies that “[p]ending OFAC enforcement matters will proceed irrespective of the termination of OFAC-administered sanctions on Burma, and OFAC will continue to review apparent violations of the [Burmese Sanctions Regulations], whether [such violations] came to the agency’s attention before or after the Burma sanctions program was terminated.” In connection with terminating the Burma-related sanctions program, OFAC made several deletions to its SDN List.

OFAC Updates Iran-Related FAQs. On October 7, OFAC updated its Frequently Asked Questions (FAQs) relating to the Listing of Certain U.S. Sanctions under the Joint Comprehensive Plan of Action (JCPOA). In addition to adding three FAQs related to due diligence (see M.10 through M.12), OFAC amended two FAQs (C.7 and C.15) regarding Financial and Banking Measures and one FAQ (K.19) related to Foreign Entities Owned or Controlled by U.S. Persons. FAQ M.10 clarifies that while “[i]t is not necessarily sanctionable for a non-U.S. person to engage in transactions with an entity that is not on the SDN List but that is minority owned, or that is controlled in whole or in part, by an Iranian or Iran-related person on the SDN List,” it is recommended that persons engaging in such transactions exercise caution to ensure that they do not involve Iranian or Iran-related persons on the SDN List. FAQs M.11 and M.12, respectively, address (i) due diligence expectations related to the screening of potential Iranian counterparties; and (ii) the circumstances under which OFAC expects a non-U.S. financial institution to repeat the due diligence their customers have already performed on an Iranian customer.

Treasury and Federal Reserve Support G-7 Elements of Cybersecurity for the Financial Sector. On October 11, the U.S. Department of the Treasury announced that the Group of Seven (G-7) countries – comprised of the United States, Canada, France, Germany, Italy, Japan, and the United Kingdom – issued fundamental elements to “help address cyber risks facing the financial sector from both entity-specific and system-wide perspectives.” In Fundamental Elements of Cybersecurity for the Financial Sector, G-7 outlines eight elements for private and public entities within the financial sector to use as “building blocks” for confronting cyber-related issues, the first of which is to establish and implement tailored cybersecurity strategies and operational frameworks that should be tailored to an entity’s nature, size, complexity, risk profile, and culture. Read more here.

Mortgages

CFPB Releases Updated TRID Compliance Guide. On October 12, the CFPB issued an updated version of its small entity compliance guide on the Know Before You Owe TILA-RESPA Integrated Disclosure (TRID) Rule. The updated TRID compliance guide incorporates guidance from CFPB webinars on various topics, including (i) record retention; (ii) Loan Estimate and Closing Disclosure requirements, including format and delivery; (iii) good faith standards and determinations; (iv) disclosures related to seller-paid costs; and (v) construction loans. The newly released TRID compliance guide replaces the CFPB’s July 2015 guide. The CFPB also issued a separate revised guide for completing the Loan Estimate and Disclosure forms.

Payments

Federal Reserve Board Member Recognizes Blockchain Technology’s Potential; Warns of Associated Risks. On October 7, at the Institute of International Finance Annual Meeting Panel on Blockchain, Federal Reserve Board member Lael Brainard delivered a speech titled “Distributed Ledger Technology: Implications for Payments, Clearing, and Settlement.” Brainard acknowledged blockchain technology as possibly the “most significant development in many years in payments, clearing, and settlement” and outlined its potential “to transform the way financial market participants transfer, store, and maintain ownership records of digitized assets.” Brainard highlighted payment technology changes as a particular regulatory focus and emphasized the Federal Reserve’s “responsibilities for promoting the safety and efficiency of the payments and settlements systems; supervising financial institutions engaged in payments, clearing and settlement; and safeguarding financial stability.” Read more here.

Firm News

Sasha Leonhardt will participate in the ABA's 7th National Institute on Consumer Finance as a faculty member on the SCRA and MLA panel on Tuesday, October 18, 2016 in Arlington, VA.

Amy Davine Kim will moderate the Money20/20 panel, "RegTech: Addressing Regulatory Challenges with Automation & Advanced Data Analytics," on Sunday, October 23, 2016 in Las Vegas, NV.

Kathleen Ryan will speak on the panel titled "The Road Ahead: HMDA and Fair Lending" at the Mortgage Bankers Association 2016 Annual Convention & Expo on Monday, October 24, 2016 in Boston, MA.

Margo Tank will speak on the "Overcoming the Final Hurdles to Digital Mortgage" panel at the Mortgage Bankers Association 2016 Annual Convention & Expo on Monday, October 24, 2016 in Boston, MA.

Doug Gansler will speak on the STAGE Network webinar, "Managing Cybersecurity Risks and the Role of State Attorneys General," on Tuesday, October 25, 2016.

John Redding will moderate the "Credit Reporting Hot Topics and Current Challenges" panel at the AFSA Annual Meeting on Wednesday, October 26, 2016 in Palm Beach, FL.

John Redding will speak on the "Compliance Roundtables: CFPB Debt Collection Proposals" panel at the AFSA Annual Meeting on Wednesday, October 26, 2016 in Palm Beach, FL.

Marshall Bell will speak on the "Fair Lending Quality Assurance and How to Prepare for a Fair Lending Exam" session at the NAFCU's Regulatory Compliance Seminar on Wednesday, October 26, 2016 in New Orleans, LA.

David Baris will speak on the "Board Matters, Corporate Governance & Shareholder Succession" panel at the Subchapter S Bank Association 19th Annual Conference on Friday, October 28, 2016 in San, Antonio, TX.

Margo Tank and David Whitaker will speak on the panel titled "The Latest in Regulations & Law" at the ESRA's eSign Records 2016 Conference in Washington, DC, on Wednesday, November 2, 2016.

James Shreve will speak on the "Business Email Compromise - Your Company's Greatest Uninsured Financial Risk" panel at the ISSA International Conference on Wednesday, November 2, 2016 in Dallas, TX.

Joshua Kotin will speak on the "HMDA: Changes are Coming" panel at the Illinois Mortgage Bankers Association's Regulatory Compliance Update on Wednesday, November 2, 2016 in Oak Brook, IL.

David Baris will speak on "The Director's Role: Risk Tolerance and Portfolio Management" panel at the WIB's Fall Bank Director Conference on Friday, November 4, 2016 in San Diego, CA.

Andrew L. Sandler and Jonice Gray Tucker will speak at the American Bankers Association's General Counsel's Meeting on Thursday, November 10, 2016 in Washington, DC.

Andrew L. Sandler will speak at the 20th Annual CRA and Fair Lending Colloquium on Tuesday, November 15, 2016 in Las Vegas, Nevada. His panel is titled "You Got Your Peanut Butter in My Chocolate! Finding a Way to Make CRA and Fair Lending Taste Great Together!"

Amy Davine Kim will moderate the "AML Governance: A Check Up On Your Program - Small Banks" panel at the ABA/ABA Money Laundering Enforcement Conference on Tuesday, November 15, 2016 in Washington, DC.

Elizabeth McGinn will speak on The Knowledge Group webinar, "Identity Theft and Data Security: Raising the Bar," on Wednesday, November 16, 2016 from 3:00 - 5:00 pm ET.

Benjamin Klubes and Michelle Rogers will speak on the "Individual Partners - Relationships and Transitions" panel at the New York City Bar Association's series on law firm succession planning on Thursday, December 1, 2016 in New York, NY.

Jonice Gray Tucker will speak on the "Consumer Financial Enforcement" panel at the PLI Banking Law Institute on Friday, December 2, 2016 in New York, NY.

Firm Publications

Benjamin Klubes, Veena Viswanatha, Kate Berlitz Shrout, and Matthew Newman co-authored "Has the Game Changed? New Considerations for General Counsel Post-Yates," which was published September 30, 2016 in Bloomberg BNA White Collar Crime Report.

Elizabeth McGinn and Tihomir Yankov co-authored "Guarding Against Privilege Waiver in Federal Investigations," which was published September 20, 2016 in Law360.

David Krakoff, James Parkinson, Lauren Randell, Veena Viswanatha, and Bree Murphy co-authored "Challenges to the DOJ's Jurisdiction Over Extraterritorial Conduct," which was published September 2016 in Business Crimes Bulletin.

Kathleen Ryan and Sherry-Maria Safchuk co-authored "5 Tips to Prepare for New HMDA Reporting," which was published August 15, 2016 in Law360.

Valerie Hletko and Sasha Leonhardt were among the co-authors of "Corporations May Be People, But They Are Not Servicemembers," which was published August 7, 2016 in Vol. 20, Iss. 7 of the Consumer Financial Services Law Report.

Elizabeth McGinn and Moorari Shah co-authored "Mortgage Industry Struggles to Avoid Vendor Management Land Mines," which was published July 11, 2016 in Bloomberg BNA.

Mark Rooney authored "Fate of Municipal-Plaintiff FHA Suits in Justices' Hands" which was published June 28, 2016 in Law360.

Margo Tank authored "Verdicts Set Important Precedent for Paperless Mortgage," which was published June 28, 2016 on eOriginal's Blog.

Michelle Rogers, Melissa Klimkiewicz, and Kathryn Contario authored "Notice of Material Event Reporting - Pitfalls for FHA Mortgagees," which was published in the June 2016 issue of the Mortgage Compliance Magazine.

Douglas Gansler and John Troost authored "You Can Run, But You Can't Hide: What to Do When a State Attorney General Comes Calling," which was published June 8, 2016 by the Nutrition Business Journal on the New Hope Network.