Quarterly News, Summer 2019
IN THIS ISSUE
Beltway Report
Page 2
Bureau Report
Page 3
Mobile & Emerging Payments Report
Page 5
Mortgage & Fair Lending Report
Page 5
Operations Report
Page 7
Preemption Report
Page 8
Privacy Report
Page 8
Arbitration Report
Page 9
TCPA Report
Page 10
BSA/AML Report
Page 11
MOFO METRICS
6
Time the average person waits at stop
lights over their lifetime, in months
20
Percentage of driving time spent waiting
at stop lights
124
Money lost in gasoline and productivity
loss due to traffic congestion per year, in
billions of dollars
5.7
Annual person-hours of delay caused by
traffic congestion in the U.S., in billions
20
Percentage of car crashes in U.S. cities
relating to searching for parking
EDITOR’S NOTE
The fireworks have started early this year. On May 2, a federal court
in New York rejected the OCC’s motion to dismiss the lawsuit
brought by the NY DFS challenging the OCC’s fintech charter. The
decision has something for everyone — ripeness, standing, state
sovereign authority, dictionary definitions, and some Chevron
deference (or lack thereof) for good measure. Exciting reading! And
after fighting about everything else, it looks as though the OCC and
the NY DFS have agreed that the next stop should be the Second
Circuit. So we can all look forward to Round 2.
Speaking of Round 2, a federal judge in Texas continued the stay of
the compliance dates for both the payments and ability-to-repay
provisions of the CFPB’s payday lending rule, as well as the stay of
the litigation brought by trade groups challenging the rule. The
CFPB issued a final rule to delay the implementation date for the
ability-to-repay portion of the rule, which is the subject of
rulemaking to rescind these requirements. The federal judge stay ed
the compliance date for both these ability-to-repay provisions and
the payments provisions of the rule over the CFPB’s objection.
It’s not looking much like the lazy days of summer in the world of
financial services. Grab a glass of lemonade and read on for updates
on Fintech, Bureau, Beltway, Mortgage, Privacy, BSA/AML, etc.
