Regulatory & Compliance

Banking

Haydn J. Richards, Jr. | Dykema Gossett PLLC

It is not often that an informal, three-page bulletin can result in substantial changes to the operations of a significant portion of the economy. However, the Consumer Financial Protection Bureau’s (“CFPB”) April 13, 2012, bulletin did just that: financial services...

Regulatory & Compliance

David P. Graham, Kristina Kaluza | Dykema Gossett PLLC

An administrative agency may only exercise the authority which Congress grants to it. Yet, as can often be the case, the grant and scope of authority Congress gives to the executive branch can be uncertain because administrative bodies need to interpret ambiguous statutes in an attempt to...

Regulatory & Compliance

Kelly Franklin Bagnall, Chais Sweat | Dykema Gossett PLLC

Imagine the following – a solidly performing hotel, diligently paying its occupancy and property taxes, that has a 95 percent customer satisfaction rating is surprised one morning by the local sheriff paying the hotel a visit. The sheriff has a posse of deputies in tow, carrying...