Tag: S. 2099

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Recently Introduced Bills to Protect Privileged Documents: Are They Sufficient to Protect Credit Unions and Nonbanks?

Recently Introduced Bills to Protect Privileged Documents: Are They Sufficient to Protect Credit Unions and Nonbanks?

By: Stephanie C. Robinson

Several bills floating around Congress this month aim to address the privilege waiver issue that is causing anxiety for CFPB-regulated entities. Banks and credit unions routinely have shared privileged documents with their prudential regulators (banking agencies and the National Credit Union Administration) without concern about a claim of waiver because of two statutory provisions that say submitting privileged information to these regulators in the course of supervision does not result in a waiver as to any other person or entity. Read More

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