Global Financial Markets

On July 30, 2024, the FDIC proposed revisions to the restrictions on brokered deposits. The revisions would undo many of the key elements of the 2020 revisions, and would dramatically expand the number of deposit brokers and the amount of deposits that are brokered. Please join Mayer Brown partners Jeffrey Taft and Matt Bisanz to understand what this rollback will mean for banks and deposit intermediaries.

Members of Mayer Brown’s Financial Services team summarize the main takeaways of the CFPB’s proposal to amend the Regulation X mortgage servicing rules.  We focus on the proposal to amend the requirements for mortgage servicers to assist borrowers in default who seek payment assistance, the proposed amendments to foreclosure safeguards during that process, and the CFPB’s proposal regarding providing certain communications in languages other than English.

On July 8, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued interpretive guidance that requires certain legal entities that have been dissolved or otherwise ceased to exist to file beneficial ownership information reports under the Corporate Transparency Act. Please join Mayer Brown partners Adam Kanter and Matt Bisanz to understand what that means and how it may impact your organization.

On March 5, the Consumer Financial Protection Bureau issued a Final Rule that would significantly restrict late fees that consumer credit card issuers may charge to a mere $8—representing approximately a 75% reduction from current levels. Within two days, the Final Rule faced a challenge in the Northern District of Texas by a coalition of trade groups including the United States Chamber of Commerce, the American Bankers Association, and the Consumer Bankers Association. The challenge seeks to invalidate the Final Rule on several constitutional, procedural, and substantive bases, as well as a temporary stay of the rule’s enforcement while the suit is litigated. Please join Mayer Brown attorneys Eric Mitzenmacher, Jan Stewart, and Joy Tsai as they discuss the rulemaking, the challenges it faces in litigation, and implications for card issuers and secondary market participants.

The CFPB has launched an aggressive campaign against so-called “junk fees.” This year the CFPB has released proposed rules targeting overdraft and non-sufficient funds fees and a final rule targeting credit card late fees. Along the same lines, two of the three latest editions of the Bureau’s Supervisory Highlights were marketed as special editions focused on junk fees. In this episode of our Global Financial Markets Podcast, Frank Doorley and Christa Bieker discuss what you need to know about the CFPB’s focus on fees that it asserts are hidden from the competitive process. 

The end of 2023 saw a barrage of major proposals and other actions by US banking regulators. Many of these are contentious issues that have divided regulators and generated significant public controversy. Final proposals of some could be coming in 2024, but only if they can avoid being crowded out by the federal elections in the fall. Please join Mayer Brown partners Jeffrey Taft and Matt Bisanz as they discuss these proposals and how they may impact the banking industry.

Please join Mayer Brown partners Tameem Zainulbhai, Joanna Nicholas, Melissa Kilcoyne, Evan DeCresce and Jim Antonopoulos for a discussion on What to Expect in 2024 in the fields of structured finance and securitization. They will examine some key challenges and opportunities this new year will bring to market participants, and discuss trending issues and topics affecting the structured finance and securitization markets. Topics include the mortgage landscape, CLOs, trends in auto and equipment asset classes, trade receivables, and recent regulatory activity.

The authors of our recent Legal Update provide an overview of the SEC’s (Securities and Exchange Commission) recently adopted rule, which prohibits conflicts of interest in certain securitizations as required under the Dodd-Frank Act. Although not perfect, the final rule is a significant improvement over the proposal. However, all securitization participants will need to assess their securitization programs and implement various compliance programs before the final rule becomes effective on June 9, 2025.

Please join Mayer Brown lawyers Stuart Litwin, Christopher Horn and Michelle Stasny as they discuss the recently adopted rule.

The Consumer Financial Protection Bureau recently proposed an extensive framework of rules to ensure consumer access to certain information at their financial institutions. The rules would require financial institutions to make certain data relating to consumers' transactions and accounts available to consumers and authorized third parties, establish obligations for third parties accessing a consumer's data, and provide basic standards for privacy, security, and data access.

Please join Mayer Brown lawyers Matt Bisanz and Kelly Truesdale as they discuss the proposal and what it means for the financial services sector.

With less than 30 days until the Corporate Transparency Act’s beneficial ownership reporting requirement takes effect, questions still abound. While only new entities will be subject to reporting requirements at first, thousands of those are formed every day who will need to understand—and apply—these new regulations with limited guidance. Please join Mayer Brown partners Brad Resnikoff and Matt Bisanz as they discuss some of the most pressing issues.