Morrison & Foerster Discusses CFPB Report on Consumer Credit Card Market

On December 27, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) released its biennial report on the consumer credit card market (“2017 Report” or “Report”), which summarizes its views on the state of the consumer credit card market over the past two years. The Report is particularly noteworthy because it provides the first insight into the post-Cordray CFPB’s views on the state of the consumer credit card market.

The Report was issued pursuant to Section 502(a) of the CARD Act (“CARD Act”),[1] which directs the CFPB to review and report on the consumer credit card market. The CARD Act … Read more

Morrison and Foerster Summarizes the Status of Dodd-Frank as it approaches three years

If Aesop were still in the fable-writing business, and he had been watching the last three years of Dodd-Frank Act rulemaking, we would probably be reading the Snail and the Tortoise to our kids. In this issue of Dodd-Frank at Three, we are, once again, inclined to direct your attention to the tortoise. At each milestone since enactment of the Act, we have noted that slow and steady implementation progress was being made by the banking agencies, the SEC and the CFTC, and we were beginning to see a new regulatory framework for financial institutions take shape. On this third … Read more

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