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A Litigator’s KISS Takeaways from CFPB’s Summer 2018 Supervisory Highlights

September 12, 2018

Authors

Douglas Thompson

A Litigator’s KISS Takeaways from CFPB’s Summer 2018 Supervisory Highlights

September 12, 2018

by: Douglas Thompson

KISS. An acronym first utilized in military equipment design in the 1960’s, “Keep it Simple Stupid.” Litigators rely on KISS in formulating trial themes and presentations to juries. Simple messages resonate. In that vein, I offer three KISS takeaways from the Bureau of Consumer Financial Protection’s Supervisory Highlights, Issue 17, Summer 2018.

KISS #1: Details Matter. 

On two key levels: (a) your business compliance operations and consumer interactions, and (b) in the Bureau’s supervision and examination conclusions. Taking these

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CFPB Issues Guidance on Confidential Supervisory Info

January 9, 2012

Authors

Bryan Cave Leighton Paisner

CFPB Issues Guidance on Confidential Supervisory Info

January 9, 2012

by: Bryan Cave Leighton Paisner

The CFPB recently issued guidance on the treatment of confidential supervisory information.  CFPB Bulletin 12-01 states that once the bureau issues a request for information, supervised financial institutions (i.e., those with total assets of more than $10 billion) are required to provide all documents and other information responsive to the request.  The bulletin adds:

Supervised institutions may not selectively withhold responsive documents based on their judgment that such materials are not necessary to the Bureau’s execution of its responsibilities or that other materials would be sufficient to suit the Bureau’s needs. The supervisory process is based on the supervisor’s

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New Supervisory Guidance on BHC's Dividends, Redemptions and Repurchases

February 25, 2009

Authors

Robert Klingler

New Supervisory Guidance on BHC's Dividends, Redemptions and Repurchases

February 25, 2009

by: Robert Klingler

On February 24, 2009, the Federal Reserve published a Supervisory Letter regarding the ability of bank holding companies to declare dividends and to redeem or repurchase equity securities.  The Supervisory Letter is generally consistent with prior guidance, although places greater emphasis on discussions with the regulators prior to dividend declarations and redemption or repurchase decisions even when not explicitly required by the regulations.  Although consultation with the Federal Reserve in these situations is optional, the guidance makes clear that the failure to consult with the Federal Reserve “could result in a supervisory finding that the organization is operating in

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