Brad Rustin

June 07, 2024 | Daily Business Review

This case was not really about nuances of constitutional appropriations but the fundamental mission of an agency that is tasked with making rules and then enforcing those rules. Unlike the traditional bank regulators that consider the safety, soundness, and overall health of the entities they supervise, the CFPB's mission is that of an enforcer—a "check" on those that are regulated.

By Brad Rustin

9 minute read

February 07, 2024 | Daily Business Review

This latest action by the CFPB follows the back-and-forth seen in the prudential bank regulators relating to the imposition of overdraft fees and insufficient funds (NSF) fees. Many bankers will recall that in August 2022, the FDIC issued guidance noting that the imposition of multiple NSF fees for the same transaction "results in heightened risks of … unfair or deceptive acts or practices (UDAP)," even when fully disclosed to the customer.

By Brad Rustin, Erin Kolmansberger, Marianna McDevitt and Lashania White

7 minute read

February 26, 2018 | Legaltech News

This article appeared in Cybersecurity Law & Strategy, an ALM publication for privacy and security professionals, Chief Information Security Officers,…

By Craig Nazzaro, Brad Rustin and Elizabeth A. DeVos, Nelson Mullins Riley & Scarborough

6 minute read

January 08, 2018 | Legaltech News

Blockchain's operational efficiencies and cost savings are equally coveted by the entities trying to implement them and by the customers who will benefit. However, neither party can fully enjoy the benefits without first understanding the various regulatory hurdles.

By Craig Nazzaro, Dowse Bradwell “Brad” Rustin, IV, and John M. Jennings, Nelson Mullins Riley & Scarborough

9 minute read