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Article

Sullivan & Cromwell LLP | USA | 16 May 2018

Bank Regulators’ Legal Authority to Compel the Production of Material That Is Protected by Attorney-Client Privilege: Banking Regulators’ Examination Authority Does Not Override Attorney-Client Privilege

Notwithstanding the venerable status of the attorney-client privilege and the important purposes it serves, the federal bank regulators and

Article

Sullivan & Cromwell LLP | USA | 18 Sep 2017

CFPB Rule Prohibits Financial Services Providers from Blocking Consumer Class Actions in Arbitration Agreements

The Consumer Financial Protection Bureau's rule, which went into effect today, (i) prohibits providers of certain consumer financial products and

Article

Sullivan & Cromwell LLP | USA | 14 Jun 2017

Treasury Issues Comprehensive Report on Depository System Regulatory Reforms

On June 12, 2017, the U.S. Department of the Treasury ("Treasury") issued a Report (the "Report") recommending a number of comprehensive changes in

Article

Sullivan & Cromwell LLP | USA | 9 Jun 2017

Financial CHOICE Act of 2017 - House Passes Financial Regulatory Reform Legislation

Late yesterday, the U.S. House of Representatives, voting almost entirely along party lines, passed H.R. 10, the "Financial CHOICE Act of 2017" (the

Article

Sullivan & Cromwell LLP | USA | 21 Apr 2017

Financial CHOICE Act "2.0"

House Financial Services Committee Chairman Releases Revised Financial Regulatory Reform Proposal

Article

Sullivan & Cromwell LLP | USA | 15 Nov 2016

2016 U.S. Presidential and Congressional Elections

The Republican Party emerged from last week's elections having won control of the White House and retained slightly reduced majorities in both

Article

Sullivan & Cromwell LLP | USA | 13 Oct 2016

D.C. Circuit Invalidates CFPB Structure as Unconstitutional; Rejects "Flawed" Statutory Application in Enforcement Proceeding

On October 11, 2016, a panel of the U.S. Court of Appeals for the D.C. Circuit held that the Consumer Financial Protection Bureau (the “CFPB”) is

Article

Sullivan & Cromwell LLP | USA | 15 Sep 2016

CFPB Proposes Amendments to Confidentiality and Disclosure Rules: CFPB Proposes Amendments to Rules Governing Disclosure of Confidential Information

On August 24, 2016, the Consumer Financial Protection Bureau (“CFPB” or the “Bureau”) announced proposed amendments to its rules governing the

Article

Sullivan & Cromwell LLP | USA | 5 Apr 2016

Regulatory Guidance Regarding FinTech Products and Services

On March 31, 2016, the Office of the Comptroller of the Currency (the “OCC”), the regulator of Federally chartered national banks and savings

Article

Sullivan & Cromwell LLP | USA | 7 Aug 2015

D.C. Circuit allows challenges to the CFPB’s constitutionality to proceed

On July 24, 2015, a panel of the U.S. Court of Appeals for the D.C. Circuit held that State National Bank of Big Spring (the “Bank”), a Texas bank

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