Podcasts about udaap

Today's podcast show is a repurposing of the second half of a webinar we produced on January 17, 2025. That webinar was Part 3 of our webinar series entitled “The Impact of the Election on the CFPB and Others.” In Part 3, we focus on the role of state attorneys general in a rapidly shifting CFPB environment. Our previous podcast show, released on Tuesday February 11th, was a repurposing of the first half of our January 17th webinar in which Alan Kaplinsky had a “fireside chat” with Matthew J. Platkin, the New Jersey Attorney General. See here. The importance of Part 3 is underscored by the recent actions taken by President Trump to fire Rohit Chopra as Director of the CFPB and to appoint new Treasury Secretary, Scott Bessent, and then new Office of Management and Budget (OMB) Director, Russell Vought, as Acting Directors, Messrs. Bessent, and Vought have essentially stopped all activities of the CFPB for the time being. During today's podcast show, Mike Kilgarriff, Joseph Schuster, Adrian King and Jenny Perkins of Ballard Spahr's Consumer Financial Services Group discussed in detail the following issues, among others: •           CFPB post-election messaging to state attorneys general providing a roadmap to them on powers they may exercise under federal law, including the use of the UDAAP provision of Dodd-Frank (particularly the “abusive” prong) •           The probable decline in collaboration with the CFPB following the change in administration •           More networking of state attorneys general •           What can we expect from state legislatures in enacting new consumer financial services protection laws? •           What can we expect from state attorneys general and other state agencies in promulgating new consumer financial services protection laws? •           The continuing need for companies to maintain a robust compliance management system Parts 1, 2 and 3 of our webinar series appear here, here, and here. Our podcast shows (repurposing Parts 1 and 2 of our webinar series) appear here, here, here, and here. The title of Part 1 is: “The Impact of the election on the CFPB: Regulations and other written guidance, which featured Alan Kaplinsky's “fireside chat” with David Silberman who held senior positions at the CFPB for almost 10 years during the Directorships of Cordray, Mulvaney, and Kraninger. Part 2 is: “The Impact of the Election on the CFPB: Supervision and Enforcement, which featured Alan Kaplinsky's “fireside chat” with former Director Kathy Kraninger during Trump‘s first term in office. Alan Kaplinsky, Senior Counsel and former chair for 25 years of the Consumer Financial Services Group, hosts the discussion.

In this third episode of the Year in Review series of The Consumer Finance Podcast, host Chris Willis is joined by Lori Sommerfield, a partner in Troutman Pepper Locke's Consumer Financial Services Practice Group, to discuss significant fair lending and Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) developments during 2024 and what to expect in 2025. They delve into aggressive redlining enforcement actions by federal regulators under the "Combatting Redlining Initiative" during the Biden administration, federal and state regulators' increasing scrutiny of the use of artificial intelligence in consumer lending and potential discrimination claims, the Consumer Financial Protection Bureau's war on "junk fees," and the current status of the Section 1071 final rule. They also offer predictions concerning anticipated changes in the federal agencies' approach to fair lending and UDAAP enforcement under the Trump administration. Tune in for a comprehensive overview and expert insights into these pivotal areas of law, which pose significant regulatory, legal, and reputational risk.

Our podcast show today features John Culhane and Mike Kilgarriff, partners in Ballard Spahr's Consumer Financial Services group. They discuss what supervision and enforcement will look like under a new acting director/director appointed by President Trump. This episode is a repurposing of the second half of a webinar that was produced on January 6. On January 23, we released the first half of the webinar, which consisted of Alan Kaplinsky's “fireside chat” with Kathy Kraninger, the former Director of the CFPB during Trump 1.0., linked here. With respect to supervision, we consider, among others, the following issues with respect to the CFPB's leadership under Trump 2.0: (a) Will it be business as usual or more relaxed? (b) Will it focus on compliance with the Federal consumer financial services laws and less on UDAAP? (c) Will there be reduced staffing and fewer exams? (d) Will there be fewer PAAR letters and more use of MRAS and MRIAs? With respect to enforcement, we consider, among others, the following issues with respect to the CFPB's leadership under Trump 2.0: (a) Will there be an exhaustive review of all existing investigations and lawsuits and a dismissal of those which involve “regulation by enforcement” or “pushing the envelope”? (b) Will they focus more on fraud and scams and less on UDAAP? (c) What position will they take on whether the CFPB has been unlawfully funded because the Federal Reserve Banks have had no combined earnings since September 2022? Alan Kaplinsky, Senior Counsel and former chair for 25 years of the Consumer Financial Services Group, hosts the discussion.

Dive into the complexities of RESPA compliance with Marx Sterbcow as he unpacks the regulatory challenges shaping the title and real estate industry. From affiliated business arrangements to the ongoing evolution of compliance, this episode offers everything you need to succeed in today's intricate regulatory landscape. What you'll learn from this episode The critical role of transparency and accuracy in affiliated business disclosure forms How industry consolidation is reshaping the title and real estate markets Why engaging with regulators builds trust and fosters compliance Emerging trends in technology and AI enforcement in regulatory actions Strategies to mitigate risks associated with marketing arrangements and social media oversights Resources mentioned in this episode Respro® October Research United States Department of Housing and Urban Development Consumer Financial Protection Bureau Office of the Comptroller of the Currency (OCC) Freddie Mac Fannie Mae Townstone Financial National Association of REALTORS® Compass Berkshire Hathaway Keller Williams RE/MAX CoStar Apartments.com LoopNet The Firm by John Grisham | Paperback, Hardcover, and Kindle No Good Deed Goes Unpunished by E. James Harrison | Paperback and Kindle About Marx Sterbcow Marx is the Managing Attorney in the New Orleans-based law firm, Sterbcow Law Group LLC. Sterbcow's practice focuses on RESPA, TILA & Regulation Z, UDAAP, Fair Lending Act, federal and state mortgage lending and consumer credit compliance issues, real estate brokerage programs, affiliated business arrangements, marketing and promotional program guidance, licensing, and lead generation compliance matters. He also represents clients in connection with mortgage fraud, RESPA, and other administrative enforcement actions.   Marx graduated from Tulane University in New Orleans, Louisiana, with a bachelor's degree in history and political science, Gonzaga University School of Law in Spokane, Washington, with a J.D., and the John Marshall School of Law's Center for Real Estate Law in Chicago, Illinois, with an LLM.   Marx represented the National Association of Mortgage Brokers in its efforts to challenge the Federal Reserve Board on its Regulation Z loan officer compensation rule. He serves on the Regulatory & Policy Committee for the Real Estate Services Providers Council (RESPRO) and is active in the Mortgage Bankers Association, American Land Title Association, Louisiana Land Title Association (Vice President 2014-15), New Orleans Metropolitan Association of Title Attorneys (Vice President) and the National Association of Mortgage Brokers. He is a frequent speaker at industry conferences. Connect with Marx Website: Sterbcow Law Group LinkedIn: Marx Sterbcow     Connect With Us Love what you're hearing? Don't miss an episode! Follow us on our social media channels and stay connected.   Explore more on our website: www.alltechnational.com/podcast Stay updated with our newsletter: www.mochoumil.com Follow Mo on LinkedIn: Mo Choumil

On May 16, 2024, the U.S. Supreme Court ruled that the CFPB's funding mechanism does not violate the Appropriations Clause of the U.S. Constitution. This two-part episode repurposes a recent webinar. In Part I, we first discuss the SCOTUS decision, the status of the CFPB's payday lending rule that was at issue in the underlying case, and a potential new challenge to the CFPB's funding that has been the focus of recent attention. We then discuss four cases still pending before SCOTUS in which the decisions could impact the CFPB. Next, we discuss the pending lawsuits challenging the CFPB's final rules on credit card late fees and small business data collection and the changes to the CFPB's UDAAP exam manual defining “unfairness” to include discrimination, including the background of those cases, their current status, and the non-constitutional legal challenges made by the plaintiffs in those cases. We conclude with a discussion of final and proposed CFPB rules expected to be issued soon and potential non-constitutional legal challenges to those rules. Alan Kaplinsky, Senior Counsel in Ballard Spahr's Consumer Financial Services Group, moderates the discussion joined by John Culhane, Richard Andreano, and Joseph Schuster, Partners in the Group, and Kristen Larson, Of Counsel in the Group.

In this episode of The Consumer Finance Podcast, Chris Willis and Josh McBeain discuss the Consumer Financial Protection Bureau's (CFPB) proposed rule on overdraft fees. The rule, which only applies to large financial institutions with assets over $10 billion, aims to regulate overdraft services by altering the definition of 'finance charge,' effectively subjecting these institutions to Regulation Z's disclosure and substantive provisions. Chris and Josh delve into the complexities of the proposed rule, considering its potential implications and the likelihood of litigation challenges from the industry. They also discuss the role of the Truth in Lending Act (TILA) and the concept of Chevron deference in this context.

In this episode of The Consumer Finance Podcast, Chris Willis discusses the Consumer Financial Protection Bureau's (CFPB) recent circular on comparison shopping and lead generation websites. The CFPB asserts that certain practices related to these websites are abusive under the Dodd Frank Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) regulation. The CFPB argues that it is abusive for website operators to influence their display or ranking of consumer financial products and services based on compensation they receive from product providers. Willis critiques the CFPB's stance, arguing that the Bureau is attempting to rewrite commerce rules by labeling practices as abusive, in conflict with long-standing regulatory guidance focused on disclosures on such websites. Despite the CFPB's circular, he suggests that the industry will likely continue to rely on appropriate disclosures to ensure consumers are informed of how products are presented in online contexts.

In this final episode of The Consumer Finance Podcast Year in Review series, host Chris Willis is joined by Tim St. George, a key member of our Consumer Financial Services Litigation team. They discuss the significant developments in consumer finance class action litigation in 2023 and what to expect in the year ahead. Topics include ethical issues associated with class actions, the debate over service awards, attorney-client privilege, and more. Tune in to gain insights from Tim's extensive experience in class action litigation and stay informed about the evolving legal landscape.To download a copy of the Consumer Financial Services Year in Review and a Look Ahead, please click here. For a list of our upcoming webinars, visit our Troutman Pepper Insights page. And to make sure you don't miss another episode of this podcast, please click subscribe.

Join us for an enlightening episode of The Consumer Finance Podcast, where we dissect the intricate world of debt collection, reflecting on the past year and forecasting future trends. This episode, hosted by Chris Willis, features insightful discussions with Stefanie Jackman and Jonathan Floyd, both well-versed in the field of debt collection. We explore significant Supreme Court cases that could reshape the collections landscape, the impact of Regulation F on validation notices, and the complexities surrounding credit reporting and medical debt. Stefanie and Jonathan share their perspectives on emerging trends and potential challenges in the collections industry. This episode is a must-listen for creditors, servicers, and collectors seeking to understand the ever-evolving landscape of debt collection. Stay tuned for the next and final episode of our Year in Review and a Look Ahead series on The Consumer Finance Podcast, providing valuable insights for anyone involved in consumer finance.To download a copy of the Consumer Financial Services Year in Review and a Look Ahead, please click here. For a list of our upcoming webinars, visit our Troutman Pepper Insights page. And to make sure you don't miss another episode of this podcast, please click subscribe.

Join us for the second episode of our Year in Review and a Look Ahead series, where we delve into the fintech world. Our host, Chris Willis, co-leader of Troutman Pepper's Consumer Financial Services Regulatory practice, is joined by James Kim who leads the firm's Fintech practice. They discuss the significant events in the fintech sector in 2023 and what to anticipate in 2024, covering key regulatory developments, the impact of the Consumer Financial Protection Bureau's proposed rules, and the increasing scrutiny of fintech-bank partnerships. Don't miss this insightful conversation as we navigate the evolving fintech landscape. Stay tuned for the next episode of our Year in Review and a Look Ahead series on The Consumer Finance Podcast, providing valuable insights for anyone involved in consumer finance.To download a copy of the Consumer Financial Services Year in Review and a Look Ahead, please click here. For a list of our upcoming webinars, visit our Troutman Pepper Insights page. And to make sure you don't miss another episode of this podcast, please click subscribe.

Please join Troutman Pepper Partners Chris Willis and Michael Lacy for a special inside look at our annual publication of the Consumer Financial Services Year in Review and Look Ahead. In our eighth year of publishing this annual review of regulatory and legal developments in the consumer financial services industry, our team has prepared a thorough analysis of the most important issues and trends across 17 consumer protection areas. For the first time, we are rolling out both webinars and podcasts on select topics to not only provide more in-depth coverage of 2023 events, but also let you know what we expect in 2024. This material will be beneficial to in-house counsel, compliance managers, regulators, and anyone in the consumer financial services space who wants to stay ahead of the curve.To download a copy of the Consumer Financial Services Year in Review and Look Ahead, please click here. For a list of our upcoming webinars, please check out our Troutman Pepper Insights page. And to make sure you don't miss another episode of this podcast, please click subscribe.

In March 2022, the Consumer Financial Protection Bureau announced that it had revised its examination manual to instruct its examiners to apply the “unfairness” standard under the Consumer Financial Protection Act to conduct considered to be discriminatory, whether or not it is covered by the Equal Credit Opportunity Act. We first review the changes that the CFPB made to the manual, its rationale for the changes, and how those changes would allow the CFPB to target discrimination more broadly than the circumstances covered by the ECOA. We also review the industry lawsuit challenging the changes, including the reasons asserted for invalidating the changes and the relief sought. We then look at the court decision vacating the changes, including the court's application of the “major questions” doctrine and the relief granted. We conclude with a discussion of the CFPB's possible next steps and the decision's implications for pending CFPB rulemakings and other CFPB actions. Alan Kaplinsky, Senior Counsel in Ballard Spahr's Consumer Financial Services Group, leads the conversation, joined by Richard Andreano, a partner in the Group and Practice Leader of the firm's Mortgage Banking Group.

In this episode, host Jenny Lee, partner at Reed Smith, speaks with guest Jonah Krane, partner at Klaros Group, about the hottest topics in fintech regulation, including how regulators can be more innovative when drafting their regulations. They discuss the latest interagency guidance on bank-fintech partnerships, the CFPB's innovation office, open banking and consumer data access, and how the Volcker rule ended up being 1,000 pages. They also cover how a principles-based approach to regulation (e.g., UDAAP) is not light touch, but actually sets a high bar (relative to prescriptive standards). And they delve into the reasons why an outcomes-based approach to consumer finance regulation should prevail, addressing the constitutional, political, or other barriers that may stand in the way.

Please join Troutman Pepper Partner Chris Willis and colleagues Keith Barnett, Carlin McCrory, and Josh McBeain as they discuss the Consumer Financial Protection Bureau's (CFPB) larger participant rule for consumer payments mentioned in its 2023 semi-annual rulemaking agenda. During this podcast, they examine a myriad of topics concerning this rule, including the following:The current trend of CFPB supervision and why the CFPB is proposing this larger participant rule;The influence on the substantive law governing some aspects of payments;The implication of CFPB examinations of payments companies for the development of the law or regulatory expectations related to Reg E;How the CFPB might use UDAAP in the payments space to drive sought-after industry changes or remediations; andThe anticipated timeline for the proposed rule.We also invite you to listen and subscribe to our new podcast, Payments Pros – The Payments Law Podcast for insights into the legal and regulatory issues facing companies in the payments industry. Click here to listen!

Please join Troutman Pepper Partner Chris Willis and his colleagues Mark Furletti, Joe Reilly, and Christine Emello for the last installment of a special three-part series about the Consumer Financial Protection Bureau's (CFPB) new small business lending data collection and reporting final rule — the Section 1071 rule. Part 3 focuses on specific areas, including highlighting those we worry will be especially troublesome for small business lenders.CFS Partner Mark Furletti focuses his practice on federal and state consumer and small business lending and payments laws, including those that apply to payment cards, buy-now-pay-later transactions, vehicle-secured loans, lines of credit, unsecured loans, and deposit products. He counsels consumer and small business financial services providers, including banks, on regulatory compliance, and defends them in class-action litigation and government supervisory and enforcement matters. He also advises merchant receivables purchasers, companies that specialize in online small business lending, and companies that interact with their customers electronically or set up recurring billing arrangements with their customers.CFS Partner Joe Reilly regularly represents lenders, fintech startups, neobanks, and mortgage servicers in enforcement matters, including informal investigations and examinations by the CFPB, OCC, Federal Reserve, FDIC, SEC, numerous state agencies, and mortgage government-sponsored enterprises, such as Fannie Mae. His compliance counseling work covers the entire range of consumer and business lending laws and rules under TILA/Reg. Z, ECOA/Reg. B, UDAAP, EFTA/Reg. E, the Fair Credit Reporting Act, debt-collection laws, GLBA privacy provisions, state licensing regimes, and others.CFS Associate Christine Emello focuses her practice on consumer financial services matters, with an emphasis on disputes, litigation, investigations, and examinations. She has worked on both federal and state court cases in jurisdictions across the U.S. She also represents banks, fintechs, and financial services companies in regulatory examinations and investigations brought by state and federal regulators, including the CFPB, the DOJ, and state attorneys general.

Please join Troutman Pepper Partner Chris Willis and his colleagues Alan Wingfield, James Kim, and Taylor Gess for the first installment of a special two-part series about the Consumer Financial Protection Bureau's (CFPB) recent policy statement on abusiveness. In Part 1 the panel discusses the background of the policy statement, the definition of abusiveness, when it exists and when it doesn't, and practical considerations for compliance.Stay tuned for Part 2 of this special series on the abusiveness statement for a deeper dive into some specific examples cited in the policy statement, as well as lessons learned about what constitutes abusiveness and what doesn't from the CFPB's perspective.CFS Partner Alan Wingfield focuses his practice on financial services litigation and consumer law compliance counseling. He helps businesses with the myriad federal and state consumer protection laws, as well as laws regulating financial services and other types of consumer-facing companies. Alan regularly represents businesses in class-action and individual consumer litigation in many national venues, particularly with the "alphabet soup" of consumer protection statutes, including Section 5 of the Federal Trade Commission Act; Dodd-Frank Wall Street Reform and Consumer Protection Act's (Dodd-Frank) Unfair, Deceptive, or Abusive Acts and Practices (UDAAP) regulation; and state equivalents of the Unfair and Deceptive Act and Practices Act (UDAP).CFS Partner James Kim leads the firm's fintech industry group. He advises fintechs, banks, investors, and other clients on federal and state consumer financial laws and regulations, including UDAAP. He helps clients navigate examinations and investigations with the CFPB, Federal Deposit Insurance Corporation (FDIC), Federal Reserve Board, Federal Trade Commission (FTC), and various state agencies. As a former CFPB senior enforcement attorney, James provides the industry knowledge and expertise that fintechs and financial institutions require when launching new products or facing regulatory scrutiny.CFS Associate Taylor Gess provides regulatory advice on matters related to federal and state consumer protection, consumer finance, and payments laws, including those that apply to payment cards, lines of credit, installment loans, electronic payments, online banking, buy-now-pay-later transactions, retail installment contracts, rental-purchase transactions, and small business loans. Taylor represents a broad spectrum of clients, such as fintech companies, banks, payment card issuers, retail merchants, online lending platforms, and solar and home improvement finance companies. In addition to handling matters on various consumer protection statutes, she also advises on issues related to payment network rules, electronic contracting, telemarketing, UDAAP, and military lending, while also helping clients develop compliance management systems, review marketing materials, and structure new products.

The recent failures of Silicon Valley Bank and Signature Bank may not be the biggest news in financial services.   In this episode, the IPA's CEO, Brian Tate, and Chris Stromberg, the IPA's director of government relations, talk about current events that could shape the future of the payments industry. They get into the Supreme Court case on the CFPB's funding, what is happening on Capitol Hill, and the CFPB's announcement on UDAAP.  The IPA thanks our member sponsor, Netspend, for helping to make this show possible.   This podcast was recorded on April 13, 2023. Things may have changed by the time you hear it.  

Under the Biden Administration, Consumer Financial Protection Bureau Director Rohit Chopra has dramatically increased the substantive reach of the CFPB's use of guidance documents and examination and supervision powers. This includes the articulation of a new standard of Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) that includes allegedly discriminatory practices. It also has announced it intends to use “dormant” powers from Dodd-Frank that would allow it to conduct supervisory exams on nonbanks or any fintech it believes is risky. Many critics argue that many of these acts should be conducted through notice and comment rule-making processes and point to similar efforts during the Obama Administration when similar extensive use of guidance was treated as equivalent to a rulemaking for purposes of the Congressional Review Act. A major lawsuit has also challenged this assertion of authority by the CFPB.In this episode, experts discuss the specifics of the CFPB's assertion of expansive authority in these areas, the use of supervision more generally in relation to rulemaking, and the lawsuit that has challenged these acts.Featuring:Brian Johnson, Managing Director, Banking Supervision and Regulation Group, Patomak Global PartnersBryan Schneider, Partner, Manatt, Phelps & Phillips, LLP[Moderator] Todd Zywicki, George Mason University Foundation Professor of Law, Antonin Scalia Law School, George Mason UniversityVisit our website – www.RegProject.org – to learn more, view all of our content, and connect with us on social media.*******As always, the Federalist Society takes no position on particular legal or public policy issues; all expressions of opinion are those of the speaker.

This podcast focuses on Compliance Management Systems. With everything coming at us from CRA, Fair Lending and UDAAP, it is imperative that financial institutions revisit CMS to ensure effective management.   Brought to you by GeoDataVision and M&M Consulting

We discuss the FDIC's final rule on misuse of the FDIC name or logo, advisory to insured banks on deposit insurance and dealings with crypto companies, and cease and desist letters to five crypto companies alleging they made false and misleading statements about deposit insurance. We also discuss the CFPB's circular warning that a misrepresentation involving the FDIC name or logo can constitute a UDAAP violation. We then identify key takeaways for banks and non-banks, including action items that should be considered for relationships involving pass-through insurance and the extent to which the FDIC name or logo can be used in advertising of credit products. Alan Kaplinsky, Ballard Spahr Senior Counsel, hosts the conversation joined by Ron Vaske, a partner in the firm's Consumer Financial Services Group, and Mindy Harris, Of Counsel in the Group.

This episode of the CRA Podcast highlights the community development work of Joshua Kummer of Bankers Trust. Joshua is the bank's CRA and Fair Banking Officer overseeing the bank's Fair Banking Program, which includes CRA, Fair Lending, HMDA, UDAAP, and Complaint Management. You will find Joshua to be very passionate about this work and this episode shares the high impact community development partnerships he has forged within his community. Not only does he have the heart for this work; you will also hear how his passion and drive has helped Bankers Trust sustain an Outstanding Community Reinvestment Act (CRA) rating!Here are the programs that are referenced within the episode:Community Development Financial Institutions (CDFI) Involvement Iowa Community CapitalSolidarity Microfinance is a non-profit program of Iowa Community Capital to create economicopportunities through small business loans, training and support, and savings services.ICC's Solidarity Microfinance program provides small loans of $500 to $8000, savings services, and financial learning opportunities for eligible low-income entrepreneurs in the Greater Des Moines Metro Area. The Solidarity Microfinance program uses Grameen peer-group lending methodology and targets women entrepreneurs from diverse new resident cultures. Neighborhood Finance CorporationNFC provides unique lending programs and other services to facilitate neighborhood revitalization in Polk County and Cedar Rapids, Iowa through partnerships with residents, governments, community-based organizations, lending institutions and the business community. For more information on our programs and services, please visit our Loan Programs page. NFC is a proud Chartered Member of NeighborWorks America. TrellisTrellis (originally started as Neighborhood Housing Services of Phoenix) was formed in 1975 with help from the City of Phoenix and NeighborWorks America. NeighborWorks America is a national nonprofit organization, federally funded by appropriations from Congress that provide financial support, technical assistance and training for community-based revitalization efforts in all 50 states.Access to homeownership is for all of us. Individuals and families become stable and more economically secure; neighborhoods become vital, active communities; and cities gain jobs and tax revenues. It's an investment with positive returns for everyone.                Other Community Involvement InitiativesHOME, Inc.HOME, Inc. is the oldest private nonprofit housing organization in Des Moines. Our mission is to meet individuals and families where they are in their housing journey. We surround our clients with compassion, support, and education so they feel empowered to make a safe, stable home for themselves or their family.  To accomplish our mission, we…– Provide counseling and education to help people become successful homeowners, landlords, and tenants.– Develop, rehab, and build affordable housing units.– Help families through counseling and education to become homeowners.          Newtown Community Development CorporationOur mission is to help people improve their financial well-being while strengthening communities through education, counseling, coaching, and the development and stewardship of permanently affordable homes.Newtown Community Development Corporation (Newtown) is a Tempe-based nonprofit founded in 1994. Newtown is recognized throughout the Phoenix Metro Area as a leading provider of homebuyer education, homeownership counseling, credit counseling, financial coaching, financial literacy education, and down-payment assistance. Newtown is a HUD-Approved Housing Counseling Agency and adheres to national industry standards for homeownership education and counseling.  Services are provided in English and Spanish.Newtown also operates an innovative Community Land Trust, which builds and renovates permanently affordable houses, providing successful homeownership opportunities for generations of lower-income families. Created in 2001, Newtown's Community Land Trust is the largest in Arizona with homes across Maricopa County.BIOJoshua Kummer is the AVP, Fair Banking Officer at Bankers Trust; Iowa's largest privately owned bank headquartered in Des Moines, Iowa with assets totaling over $6 billion. The bank operates branches in Central Iowa, Cedar Rapids, IA, and Phoenix, AZ, as has offices in Omaha, NE and Sioux Falls, SD. Joshua started his banking career over 11 years ago as a part-time teller while attending college. Since then, he's held various positions including Personal Banker, Sales & Service Manager, Branch Manager, CRA Officer and now Fair Banking Officer. He holds two compliance-related certifications: Certified Community Bank Compliance Officer (CCBCO) and Fair Lending Expert (FLE). He is also involved in his community and currently sits on the Neighborhood Finance Corporation Board of Directors, Greater DesMoines Habitat for Humanity Access to Credit Committee, Iowa Bankers Association DEI Committee and Special Olympics Iowa Fundraising Committee. Joshua has a passion for ensuring customers receive fair and equitable treatment while banking with Bankers Trust and advocates for those with limited financialresources. Bankers Trust: As Iowa's largest privately owned bank, Bankers Trust serves the personal and business banking, lending and wealth management needs of our community.Bankers Trust Core Value: CommunityWe will strive to be the best corporate citizen by supporting diverse community organizations, both financially and through employee volunteerism. We invest in the community by nurturing and encouraging growth, stability and continued success.

Jon Hill was among a group of reporters to whom Director Chopra recently gave a series of interviews in which he provided significant insights into his views on a range of topics. We review recent CFPB and other agency developments that provide context for Mr. Chopra's comments, discuss what his comments reveal about his approach to use of CFPB authorities, and highlight the important takeaways for banks and other companies. Topics covered include entry of big tech into financial services, Section 1033 rulemaking, application of UDAAP to discrimination, Military Lending Act, bank/nonbank partnerships, buy-now-pay-later, payday lending, overdraft/NSF fees, and artificial intelligence/machine learning. Alan Kaplinsky, Ballard Spahr Senior Counsel, hosts the conversation joined by Michael Gordon and Ronald Vaske, partners in the firm's Consumer Financial Services Group, and Mindy Harris, Brian Turetsky, and Rinaldo Martinez, Of Counsel to the Group.

We first review the views expressed by Director Chopra and CFPB actions taken under his leadership that led the Chamber to launch its campaign. We then discuss the campaign's specific components, which consist of digital ads, Freedom of Information Act requests, and letters to Director Chopra. Our discussion includes an in-depth look at the basis for the Chamber's view that the CFPB has acted unlawfully in connection with changes to its UDAAP examination procedures, revisions to its rules for administrative proceedings, rule change to make public a decision establishing risk-based supervision of a company, and its interpretive rule on enforcement of federal consumer financial protection laws by state attorney generals. We also discuss the litigation challenging the constitutionality of the CFPB's funding. Alan Kaplinsky, Ballard Spahr Senior Counsel, hosts the conversation.

In a recent consent order with a national bank, the CFPB found that the bank committed UDAAP violations in its process for handling garnishment orders and by including certain waiver language in its deposit account agreements. We discuss the specific aspects of the bank's process that the CFPB found to be improper and what banks should consider when reviewing their own garnishment procedures in light of the consent order. We also look at what the consent order means for how banks can address liability concerns arising out of the handling of garnishment orders in deposit account agreements. Alan Kaplinsky, Ballard Spahr Senior Counsel, hosts the conversation, joined by Mike Gordon, a partner in the firm's Consumer Financial Services Group, and Jessica Simon, Of Counsel in the firm's Bankruptcy and Restructuring Group.

This podcast will discuss the CFPB's new application of Unfairness under UDAAP. Brought to you by GeoDataVision and M&M Consulting

Ms. Twohig, a recognized consumer finance expert, shares her insights regarding the CFPB's supervisory program. Our discussion topics include: the differences between the CFPB's supervisory program and the programs of the federal and state banking regulators; the CFPB's approach to allocating resources, conducting exams, and examiner training; the origins and objectives of Supervisory Highlights; how the CFPB's supervisory focus has changed over time and the impact of leadership changes; and the CFPB's recent announcements regarding use of its risk-based supervisory authority for nonbanks and use of UDAAP to combat non-credit discrimination. Alan Kaplinsky, Ballard Spahr Senior Counsel, hosts the conversation.

We first share our perspective on Director Chopra's approach to his leadership role and use of the CFPB's authority, his priorities, and political dynamics impacting the CFPB. We then discuss the CFPB's activity during Director Chopra's initial months in office, including its request for information on “junk fees” and criticism of overdraft and credit card late fee practices, requests to large tech firms regarding payment services, fintech focus (and use of risk-based supervision), use of UDAAP to address market competition, orders seeking information from buy-now-pay-later companies, changes to UDAAP exam procedures to target non-credit discrimination, encouragement of state AGs, exams of institutional student lending, and injunctive relief focus. Alan Kaplinsky, Ballard Spahr Senior Counsel, hosts the conversation, joined by Michael Gordon and Tom Burke, partners in the firm's Consumer Financial Services Group, and Michelle Hogan, an associate in the firm's Litigation Group.

This podcast discusses recent enforcement issues with Overdraft programs and UDAAP implications.   Brought to you by GeoDataVision and M&M Consulting

The CFPB recently announced that it is updating its exam manual to direct its examiners to consider discriminatory conduct an “unfair” act or practice represents a significant expansion of its UDAAP authority. We discuss: the CFPB's legal theory; types of products/services/bases for discrimination the CFPB could reach using unfairness and role of disparate impact analysis; what manual updates tell examiners to ask about and look at; implications for entities the CFPB does not supervise or have jurisdiction over; likely legal challenges to the Bureau's theory; and how companies can prepare. Alan Kaplinsky, Ballard Spahr Senior Counsel, hosts the conversation, joined by John Culhane and Ron Vaske, partners in the firm's Consumer Financial Services Group, and Heather Klein, Of Counsel in the Group.

Professor Peterson, who served at the CFPB under former Director Cordray, shares his perspective on the CFPB's publicly-announced enforcement activities and initiatives under Director Chopra and what they might signal for future enforcement and supervisory activities. The matters discussed include the UDAAP implications of the CFPB's focus on pricing in its enforcement action against JPay, the CFPB's use of UDAAP to challenge discrimination not involving credit, and the CFPB's junk fees initiative and approach to technology. We also discuss the current status of federal and state rate cap legislation and “true lender” challenges to bank/nonbank partnerships. Alan Kaplinsky, Ballard Spahr Senior Counsel, hosts the conversation.

Late last year, a federal district court ruled that securitization trusts holding student loans might be liable for the alleged unfair and deceptive collection practices of the trusts' servicers. This is the first time that the US Consumer Financial Protection Bureau (CFPB) has sought to hold a securitization trust liable for acts of its servicers and the first judicial decision addressing the CFPB's argument that such trusts are covered persons subject to the CFPB's UDAAP authority. The decision could have broad-ranging implications not just for this asset class but for the securitization of consumer loans generally. Mayer Brown partners Barbara Goodstein, Ori Lev and Steve Kaplan discuss the background of the case, the court's recent ruling and the potential implications for both primary and secondary market participants in consumer loan securitizations.

In this wide-ranging conversation with two experienced reporters on the consumer finance industry, we discuss differences between the current CFPB and the Trump-era CFPB, including with regard to areas of regulatory and enforcement focus such as UDAAP, consumer access to financial information, small business issues, and fair lending. We also discuss the potential implications of the current CFPB's interest in buy-now-pay-later and its inquiry into large technology companies that offer payment services. Other topics include the potential impact of the recent leadership turmoil at the FDIC and expectations for activity by state regulators and attorneys general. Alan Kaplinsky, Ballard Spahr Senior Counsel, hosts the conversation.

This podcast will highlight the challenges and regulatory expectations with UDAAP. Brought to you by GeoDataVision and M&M Consulting

UDAAP is an acronym and it stands for unfair, deceptive, abusive acts and practices. Every state has their own UDAAP law and UDAAP laws became important after the 2008 financial crisis. Under each state's UDAAP law, and each state is slightly different, consumers have the right to go after big companies for deceptive practices, unfair practices, false advertising. So for example, most of my clients we help under UDAAP statutes, we're going after cable companies, internet companies, security systems, cell phone providers, getting people money damages for their out-of-pocket costs. And then the state UDAAP statutes have what's called a fee shift provision, so the other side who we're suing, pays our fees and costs. Our clients don't pay us a dime.

We are joined by Ena Koukourinis, Senior Counsel in the Bureau’s Office of Fair Lending and Equal Opportunity, and Frank Vespa-Papaleo, the Office’s Deputy Director. We discuss the statement’s background and goals, the fair lending and UDAAP concerns the statement seeks to address, key aspects of the guidance it provides, and Bureau resources available to industry concerning LEP consumers.  Chris Willis, Co-Chair of Ballard Spahr’s Consumer Financial Services Group, hosts the conversation.

Georgetown Professor Adam Levitin stops by Clark Hill’s Credit Eco to Go to provide his objective perspective on the CFPB's Final Debt Collection Rule. Overall Adam supports a having clear rules of the road, regardless of whether you agree with the rule itself. He agrees that having a rule that provides guidance for debt collectors to navigate the electronic ecosystem is very important and was glad to see that a model validation was finalized but believes it will be tweaked over time. Adam does have concerns about the frequency limits with regard to attempts to communicate by telephone and worries that repeated and unwanted calls find their way into harassment. Finally, Adam was very surprised that the CFPB did not move forward with a final rule on time-barred debt but suspects the issue may still be addressed down the road, maybe in a UDAAP rulemaking. The conversation about debt collection and the debt collection rule may be headed into extra innings. DISCLAIMER – No information contained in this Podcast or on this Website shall constitute financial, investment, legal and/or other professional advice and that no professional relationship of any kind is created between you and podcast host, the guests or Clark Hill PLC. You are urged to speak with your financial, investment, or legal advisors before making any investment or legal decisions. Funk Game Loop by Kevin MacLeodLink: https://incompetech.filmmusic.io/song/3787-funk-game-loopLicense: http://creativecommons.org/licenses/by/4.0/

Our podcast looks at types of alternative data (AD) and industry sources, key points of the recent interagency statement on using AD for credit decisions and CFPB actions to encourage such use, FCRA/ECOA/UDAAP concerns and steps to address them, use of social media data, and the relationship between AD and artificial intelligence. We also assess the regulatory concerns impeding industry’s use of AD.

In this podcast, we take a close look at the CFPB’s findings on ancillary product refunds by auto loan servicers in the event of total loss or repossession, consider such findings’ implications for early payoffs and a servicer’s duty to request refunds, and share observations on how the CPPB’s use of its UDAAP authority has changed under post-Cordray leadership and what that means for a company’s approach to compliance.    

Since becoming one of the primary points of focus for the Consumer Financial Protection Bureau (CFPB), UDAAP has presented some concern to third party risk professionals. In this podcast we cover procedures and best practices to effectively manage UDAAP and your third parties.

What you need to know about Unfair Deceptive or Abusive Acts and Practices) and how they effect your third party risk management program.

Learn from our Chief Risk Officer about Unfair, Deceptive, Abusive Acts and Practices, the role of the CFPB and enforcement actions in the world of third party risk.

Resale Value is paramount UDAAP review More stats Upside down and resale value? Is resale part of the deal? What seems like a good deal, NOT! Biggest cost, considered the least What affects resale? Predictable resale? What are all the factors? You can control much of it Part of the due diligence

This episode is incredibly special, in two ways. First, Lyn Farrell is not only my former colleague, but one of my very best friends. We had such fun recording this at my apartment in Boston one weekend late last year. In many ways, it’s just a slice of a long conversation we’ve been having more or less continuously for years, including over countless meals on the road together, in the consulting life we used to share Second, I love it when our podcast discussions are actual brainstorming sessions. This one hit the jackpot on that front. In our back and forth, Lyn came up with an insight that neither of us had when we started, and both of us have found it reshaping our thinking ever since. It comes late in the episode -- you’ll know it when you hear it. I hope you find it as powerful as we did.   Lyn Farrell is former Managing Director, and now Advisory Board Member, at Treliant Risk Advisors.  She is arguably the foremost expert in the United States on regulatory compliance matters regarding consumer financial protection. As we note in our discussion, she literally “wrote the book” on compliance as the author, for more than twenty years, of the Reference Guide to Regulatory Compliance, published by the American Bankers Association as the foundation material that candidates must master in order to become Certified Regulatory Compliance Managers. Lyn is an attorney, in-demand public speaker, prolific writer, and consultant who has worked with every imaginable regulatory challenge, from the world’s largest banks to small community institutions and fintech startups, and from positive, proactive clients to cleaning up grizzly enforcement problems. She has, simply, seen everything. Fortunately for us, she has opinions about it all and shares them with bracing candor in our talk. She describes what’s failing in our current regulatory regime and explains what everybody is getting right and getting wrong, from Congress and regulators to bank CEO’s to compliance and risk professionals to IT departments, to her fellow lawyers, to fintech innovators. She offers a cogent indictment, from the inside, of the weaknesses of what we’ve built -- the disclosures no one reads, the high costs of compliance, and the tragic mismatch between where we expend resources versus what consumers actually need. She’s also expert in bank IT operations. It’s an open secret that most banks have antiquated IT, often accumulated through decades of mergers and acquisitions in which older systems were never integrated but rather, as Lyn puts it, stuck together with “bailing wire.” (We explored solving some of this through blockchain technology in my earlier Podcast with Blythe Masters of Digital Asset Holdings.) These old systems are a hotbed of compliance errors, for reasons she describes. It’s another area where startups have a counterintuitive advantage over banks, thanks to having no creaky legacy IT. In our discussion, Lyn explores the regulatory present and past (it’s been a long time since I’ve heard anyone mention Regulation Q!), but she’s most thought-provoking about the future.  She works extensively with innovators and has a vision for how we should be using new data and technology to do better. I always urge people interested in innovation to break out of their work silos and reach across disparate realms.  Lyn does this better than anyone I know. If it weren’t for her, I would never have attended a LEAN seminar, or done free-writing exercises to inspire creative thinking, or read Deep Work by Cal Newport, or watched the Amy Cuddy Ted Talk on “presence.” Since we made our recording, Lyn has stepped back from her full time role at Treliant to serve on its advisory board, spend more time in the beautiful house she and her husband Brian are building in Colorado Springs, and lead the Treliant Institute for Strategic Compliance Leadership, her brainchild.  Lyn asked me to speak at it, which inspired me to create a dinner talk I call “Heroic Compliance.”  It’s about the need for compliance officers -- even though they often seem more like Clark Kent than Superman -- to save their banks, customers, and industry by leading them into the high-tech innovation age. No one embodies that leadership more than Lyn, and I’m titling this episode with the same name -- Heroic Compliance. The same day we recorded this episode, Lyn told me she’s launching her own podcast show, aimed at compliance professionals. She said my dinner speech prompted her to give it the name, “Compliance Heroes.” You’ll find it on ITunes and the Android Market. Here are two more titles in Lyn’s recommended reading: Emotional Intelligence 2.0  by Travis Bradberry Presence by Amy Cuddy     And here is more on her background…. Kathlyn L. Farrell, CRCM, CAMS, AMLP Senior Advisory Board Member Lyn Farrell is an experienced Regulatory Compliance executive, with over 35 years of experience in banking law and compliance. She is a Senior Advisory Board Member at Treliant Risk Advisors, LLC. Lyn has led many diverse and complex compliance projects for large financial institutions, including: Developing a regulatory compliance strategic plan for a financial institution that primarily operates in the Fintech space; Assisting the CCO of a top 10 U.S. bank to make the regulatory compliance program more proactive, strategic and integrated with the businesses and other risk management disciplines within the organization; Designing and building a comprehensive Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) audit program for the internal audit division of a top 10 U.S. financial institution, including developing the annual audit plan, scoping the individual audits, and writing the audit scripts; Assisting a top 20 bank implement all aspects of the TILA-RESPA Integrated Disclosure Rule (TRID), including revamping business processes, enhancing risk controls, writing policies and procedures and creating job aids to assist first line staff to implement this complex regulation; Developing the “UDAAP University” training program for the compliance departments at three of the top 20 financial institutions and for the internal audit departments at 3 of the top 20 US banks; Overhauled the Community Reinvestment Act (CRA) program for a top 20 US financial institution, including writing a new program document, reviewing its assessment areas and investments, and implementing a shift in the critical focus of its nationwide community development staff; Reviewing the potential acquisition by a top 20 U.S. bank of a large non-bank financial organization and provided advice on limiting the company’s regulatory risk by integrating and expanding the current compliance function and making it more strategic in its execution. Lyn has a passion for leadership development and has designed the Treliant Institute for Strategic Compliance Leadership, a leadership program exclusively for compliance professionals in financial institutions She is a frequent speaker at banking events and regularly publishes articles on a variety of banking-related topics. Her recent publications include: “Strengthening the First Line of Defense” in ABA Bank Compliance magazine, September-October 2016“TRID: A Checklist for Successful Compliance” in Mortgage Banking magazine, March 2016 Reference Guide to Regulatory Compliance, published by the American Bankers Association, the official study guide to the CRCM examination “Is this UDAAP or Not?” in  ABA Bank Compliance magazine, July-August 2015 “FCRA: A Sleeping Regulation Awakes” in Banking Exchange, August 2015 “Effectively Managing UDAAP Compliance in Mortgage Servicing” in Mortgage Banking magazine, April 2015 “Managing UDAAP Compliance Risks in Financial Institutions” in Journal of Taxation and Regulation of Financial Institutions, Nov/Dec, 2013 She received her undergraduate degree from Texas A&M University and her JD from the University of Houston.  Lyn is a Certified Regulatory Compliance Manager (CRCM), and an attorney, licensed in the state of Texas.   Lyn was the 2012 recipient of the ABA’s Distinguished Service Award. More for our listeners: I'll hope to see you all this week at FinXTech Summit in New York and of course CFSI’s Emerge in June. Remember to review Barefoot Innovation on ITunes, and please sign up to get emails on new podcasts and my newsletter and blog posts at  jsbarefoot.com.   Also go to jsbarefoot.com to send in your “buck a show” to keep Barefoot Innovation going. Please also join my facebook fan page, and follow me on twitter. Support our Podcast - Send "a buck a show" I’m just back from London -- more on that later -- but one highlight is I recorded an episode with the one and only Brett King. Coming soon! Subscribe Sign up with your email address to receive news and updates. Email Address Sign Up We respect your privacy. Thank you!

My guests today are two of the most thoughtful people in the United States on the topic of regulatory compliance. They are the chief compliance officers of Citigroup and Wells Fargo – Kathryn Reimann and Yvette Hollingsworth Clark. Our listeners include a lot of people who are not fascinated by the topic of regulatory compliance, to put it mildly. The fact is, though, that compliance has shifted, rather suddenly, from being boring to most people, to being fascinating. And whether it fascinates you or not, it has become absolutely critical to whether financial companies can thrive. Becoming great at compliance – both effective and efficient -- has become mission-critical competencies for every financial company, large and small. Let’s step back and think about what’s happening.  Technology is disrupting finance, which means that it’s also disrupting financial regulation, which therefore means that it’s also disrupting compliance, inevitably. It will completely change how financial companies implement the massive set of regulatory requirements that pervade every aspect of what they do. This is going to be – already is – a wrenching process. For better or worse, consumer financial protection regulation has always been hypertechnical. built mainly around highly prescriptive rules. Congress passes laws, the regulatory agencies issue regulations to implement them, and the industry implements the regulations. I’ve spent much of my career in this field and have watched it mature into a major function – major cost center – in every bank, into a profession of experts, and into an industry of technology vendors and consultants and lawyers who help financial companies follow these rules. With a few exceptions, the system is about getting the details right. That’s still true, of course. We still have voluminous, detailed rules aimed at consumer protection. But the financial crisis shifted the ground under this whole system, by supplementing the traditional “rules-based” system with a new “principles-based” overlay that aggressively requires that financial products be not only “compliant,” but also “fair” – able to meet heightened prohibitions on practices that are unfair, deception or abusive (which we in the compliance world, with our habit of using acornyms, call, “UDAAP.” And then, as if that weren’t a big enough change, the financial world has now also been hit with a second huge wave of change, in technology innovation. And it’s even more challenging than the shift from rules to principles, because it’s coming faster, and it’s even more unknowable than regulatory change. All this means we’ve entered into a state of permanent uncertainty. The products and market and technology are changing too fast for the legislative and regulatory process to keep pace. The regulatory process can’t, and won’t, provide clarity on exactly what the industry has to do. Instead, it will review what has been done and will, after the fact, penalize actions that are judged to have been illegal because they’re subjectively determined to have been unfair, deceptive, abusive, or discriminatory in effect. The result is that financial companies are going to have to build a whole new kind of compliance model. They won’t have the luxury of waiting for clear-cut rules. They’ll have to figure out for themselves how regulators may react to rapid change, and make their own decisions, in the absence of clear guidance, about what is risky. This requires a full overhaul of the traditional compliance model. For one thing, it means deeply, actively engaging the CEO, the board, and the business-side leadership of every company in proactively managing regulatory risk. They can’t delegate it and assume that their experts and technology will take care of it. They have to make their own decisions, and they have to do it not reactively, but proactively. Again, they’ll have to think for themselves. And they’ll also have to adopt a new generation of regtech solutions, which are starting to emerge to improve outcomes and cut costs. There’s a lot to say about what’s ahead on all this, but for today, we’re going to pick the brains of two of the most impressive leaders anywhere in the compliance world.  Yvette Hollingsworth Clark is the chief compliance officer of Wells Fargo, and Kathryn Reimann leads this work for Citigroup. I’ve known them both for years, and I was lucky enough to catch them together while we were all at the same event, and carve out some time to talk. Listen to their views on how compliance is changing, the impact of technology, and the need to bring a “fairness” lens to absolutely every regulatory question. They talk about how to do that, including how to integrate teams that can bake it into daily decision-making. They talk about the challenges arising because of the accelerating the speed of change. And they discuss the challenges of working with old legacy IT systems that were created long before today’s regulations and technology. They talk about the need for a level regulatory playing field for banks and nonbanks, how to work with regulators, and advice for regulators. They also talk about their own journeys – Kathryn notes that when she started working as a lawyer, the compliance profession didn’t even exist. We’ve come a long way. These are people who are pioneering new ways of tackling compliance. They’re doing it in some of the world’s biggest, most complex, and most highly-regulated companies, but their insights apply to every financial company – large and small, and old or brand new. Also…. Vote for my panel on the SXSW PanelPicker! I need your help getting my panel selected for inclusion in South By Southwest – SXSW – the huge technology conference that runs in Austin TX each year in conjunction with the famous music and film festival. I attended SXSW (“South by,” as people call it) for the first time last year, and it was absolutely fascinating. It’s unique among the conferences I attend, in that it’s broader than finance. It’s about technology overall. I believe fintech is more tech than fin, in the sense that it’s being driven by enormous and converging technology trends. We in the financial realm tend to underestimate how big these are and how fast they’re moving, because we think of them in terms of the financial products they’re reshaping – but they’re much bigger than those. SX is a great place to go to learn and think about these wider trends, while also seeing the most interesting new things emerging in fintech, as well. So I have proposed a panel discussion there on RegTech – the shift toward using new generation technology to get to win/wins on regulation, by reducing regulatory costs and burdens while improving outcomes for customers at the same time. I’m calling the panel REGULATION INNOVATION and my amazing guests will be Josh Reich, the CEO of Simple; Jennifer Tescher, CEO of CFSI; and Adrienne Harris of the White House. Last year, SX received 4,600 proposals, so, I need you to vote for the session on the SX Panel Picker. Voting opens up on Monday, August 8 and closes September 2. Please Google the SXSW PanelPicker during that time period, and vote for session called Regulation Innovation. And then plan to come to SX, which is 3/6-10 in Austin. I’ve been thinking maybe we should take a group of financial folks. What do you think? You can vote for it HERE   Support the podcast Please support the show! Last but not least, thanks so very much to those who have sent in your “buck a show," as we call it, to support Barefoot Innovation. Donations are essential to keep the show going, since it’s taken on a life of its own and requires a massive effort to produce. And also, please be sure to like the show on whatever ITunes or wherever you listen to it. We’ll see you soon with some incredibly interesting new guests – startups, banks, and even someone from Harvard. Til next time! As Kathryn rightly states, such an overhaul of the system requires updating perspectives of themselves and of their hires. It also requires a great degree of inter-departmental collaboration and communication. This is something that I have seen to be true all across the map of regulation - open dialogue is essential. In a previous podcast, Thomas Curry, the Comptroller of Currency and head of the taskforce on responsible innovation agrees. Kathryn and Yvette explain that compliance officers have a very tough job ahead, and I couldn't agree more. They have to balance a fine line between assessing and preventing massive risk from such huge amounts of data sharing while not becoming an obstacle to innovation. As Yvette states, we want to use innovation to regulate innovation. Important links: Citi Wells Fargo Subscribe Sign up with your email address to receive news and updates. Email Address Sign Up We respect your privacy. Thank you!