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Entries in consumer financial laws (2)


FTC Issues Interim Rule Amending the Scope of its Identify Theft "Red Flags" Rule

The Federal Trade Commission (“FTC”) recently issued an interim final rule amending its “Red Flags Rule,” 16 C.F.R. Part 681. The amendment, which affects “creditors” under the FTC’s jurisdiction, limits the applicability of the Rule by making reference to a new definition of “creditor” in Section 1681m(e)(4) of the Fair Credit Reporting Act (“FCRA”). Section 1681m(e)(4) was part of the “Red Flag Program Clarification Act” enacted by Congress in December of 2010. The FTC’s interim rule directly references this new definition, discussed below...

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Federal banking regulators announce methodology for determining asset size for purposes of enforcing federal consumer financial laws

On November 17, 2011, five federal banking agencies issued a Supervisory Ruling explaining how asset size for financial institutions would be determined for purposes of determining an institution’s primary regulator for federal consumer financial law.

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