Remove compliance supervisory-guidance
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FINRA Issues Guidance Clarifying Liability for Chief Compliance Officers

Troutman Sanders

On March 17, the Financial Industry Regulatory Authority (FINRA) issued a notice, clarifying when chief compliance officers (CCOs) will face liability as supervisors under FINRA Rule 3110. [1] 2] Ultimate responsibility for supervisory obligations in Rule 3110 lies with a member firm’s president, CEO, or equivalent officer or individual.

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SEC Record Retention Enforcement Actions

Troutman Sanders

She has counseled a national consumer reporting agency through its CFPB compliance obligations, including conducting risk assessments of consumer products and services, updating policies and procedures, and establishing an audit process to assess compliance with federal consumer financial laws.

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FINRA Vendor-Management Guidance: You Can’t Outsource Responsibility

Burr Forman

On August 13, 2021, the Financial Industry Regulatory Authority (“FINRA”) issued Regulatory Notice 21-29, collecting guidance on outsourcing and vendor management. The Notice reminds firms that while they can outsource task or functions, they cannot outsource-away their regulatory compliance obligations.

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DOJ’s Recent Guidance on Website Accessibility and the ADA — What Does It Tell Us?

Troutman Sanders

Department of Justice’s recent guidance on website accessibility for state and local governments and for public accommodations under Titles II and III of the Americans with Disabilities Act.

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CFPB Warns Auto Finance Companies About Inadvertent Repossessions

Troutman Sanders

For the most part, the bulletin reminds the industry of guidance previously issued by the CFPB in several editions of Supervisory Highlights and a 2020 consent order, but it also stands as a clear reminder that inadvertent repossessions remain one of the Bureau’s highest priorities in auto finance.

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Recent Developments in ADA Website Accessibility Compliance

Troutman Sanders

She has deep expertise in fair lending and responsible banking regulatory compliance, and she routinely counsels clients in consumer financial services supervisory issues, examinations, investigations, and enforcement actions. Transcript: Recent Developments in ADA Website Accessibility Compliance (PDF).

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CFPB To Maintain Credit Reporting Guidance Issued in April

Troutman Sanders

We reported in September of this year on a demand from multiple consumer advocacy groups to the Consumer Financial Protection Bureau (“CFPB”) to rescind its April 1, 2020, credit report guidance that relaxed the Fair Credit Reporting Act’s (“FCRA”) deadlines to investigate consumer-initiated direct disputes.

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