Subject to Inquiry

Latest from Subject to Inquiry - Page 23

TheGovernment-Regulatory-and-Criminal-Investigations.jpg CFPB’s imposition of its auto lending guidelines, and use of its admittedly flawed proxy-methodology to determine discriminatory lending in auto finance, may come to an end under the GOP controlled White House and Senate.

The CFPB’s current guidance, published in a March 2013 Bulletin, has been largely criticized as limiting competition and increasing

UK Bribery ActThe UK Government introduced the Criminal Finances Bill to Parliament today (13 October 2016), which will now start its passage through the parliamentary approval process before becoming law.
The Government hopes that the Bill “will significantly improve the government’s ability to tackle money laundering and corruption, recover the proceeds of crime, and counter terrorist financing”, and

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The Consumer Financial Protection Bureau (“CFPB”) recently issued 293 pages of proposed changes (the “Amendments”) to the federal mortgage disclosure requirements it propounded in October 2015 commonly known as the TILA/RESPA Integrated Disclosure (“TRID”) or “Know Before You Owe” rule.  The changes are many, but the rulemaking is not intended to review policy decisions behind

On July 14, Government-Regulatory-and-Criminal-Investigations.jpg2016, the Securities and Exchange Commission announced the settlement of an enforcement action against RiverFront Investment Group (“RiverFront”), an investment advisory firm, for failing to properly prepare clients for transaction costs.

At issue is a wrap fee program, in which a subadviser uses a sponsoring brokerage firm to execute their trades on

Passport-mapThe Department of Justice has raised the bar on penalties for violations of federal immigration law.  On June 30, 2016, DOJ issued an interim final rule that goes into effect on August 1, 2016.  This rule, implemented as an inflation adjustment, increases the fines for employing unauthorized workers, for Form I-9 paperwork violations, and for

ForeignCorruptIn April 2016, the Department of Justice (DOJ) announced its Foreign Corrupt Practices Act Enforcement Plan and Guidance, which includes a one-year pilot program to incentivize individuals and companies to voluntarily self-disclose Foreign Corrupt Practices Act-related (FCPA) misconduct, cooperate with DOJ investigations and remediate controls and compliance programs.  Under the guidance, the DOJ may