A second circuit court ruling invalidating one of President Obama’s recess appointments to the National Labor Relations Board could provide additional ammunition to anyone inclined to challenge the validity of his choice to...more
5/24/2013
- Canning v NLRB CFPB NLRB Recess Appointments
We have been critical of the failure of the CFPB’s white paper on payday and deposit advance loans to address the very real benefits of payday loans or the question whether (and when) such benefits outweigh the costs....more
5/21/2013
- CFPB Deposit Advances Payday Loans
Last week, the Solicitor General finally filed his brief expressing the views of the United States on whether the U.S. Supreme Court should grant the petition for certiorari pending in Township of Mount Holly v. Mt. Holly...more
5/21/2013
The CFPB has issued a proposal to temporarily delay the June 1, 2013 effective date of the Regulation Z prohibition on financing credit insurance premiums (Section 1026.36(i)). The proposal responds to concerns raised by...more
5/13/2013
- CFPB Dodd-Frank Final Rules Premiums Regulation Z
The Consumer Financial Protection Bureau has finalized revisions to its remittance transfers rule and set October 28, 2013, as the rule’s new effective date. While not entirely eliminating the requirement for remittance...more
5/8/2013
- CFPB Disclosure Requirements Remittance Transfer Rule
The CFPB’s white paper on payday and deposit advance loans received well-deserved criticism in a letter to Director Cordray from the Community Financial Services Association of America (CFSA), a national trade organization...more
5/7/2013
- CFPB Deposit Advances Payday Loans Richard Cordray
The CFPB and FTC have announced that they will co-host a roundtable on June 6, 2013 in Washington, D.C. to examine the flow of consumer data throughout the debt collection process. Titled “Life of a Debt: Data Integrity in...more
5/6/2013
- CFPB Debt Collection FTC Roundtable
Last Friday, the CFPB simultaneously issued a final rule to govern the administration of the Bureau’s Civil Penalty Fund (CPF) and proposed revisions to that rule. The final rule is effective immediately upon publication in...more
5/1/2013
- CFPB Civil Penalty Fund Dodd-Frank
Remarks made by Ori Lev, the CFPB’s Deputy Enforcement Director for Litigation, at the ABA Consumer Financial Services Committee’s spring meeting last week further clarified the role of CFPB enforcement attorneys in CFPB...more
4/10/2013
- CFPB Enforcement Attorneys
Last April, the CFPB announced that it was beginning its study of consumer arbitration as mandated by Section 1028 of the Dodd-Frank Act. Last week, nearly a year after that announcement, David Silberman, the CFPB’s Associate...more
4/8/2013
- Arbitration CFPB Dodd-Frank Request For Information
The CFPB’s announcement last Thursday that it had expanded its public Consumer Complaint Database to include complaints about products other than credit cards was accompanied by the release of four items.
...more
4/3/2013
- CFPB Consumer Complaint System
The Consumer Financial Protection Bureau has expanded its public Consumer Complaint Database to include complaints about mortgages, bank deposit products and services, student loans, and other consumer loans (which category...more
4/1/2013
- CFPB Consumer Complaint System Loans Mortgages Student Loans
The Consumer Financial Protection Bureau’s second annual report to Congress on enforcement of the Fair Debt Collection Practices Act (FDCPA) confirms that debt collection will continue to be a major CFPB focus in 2013....more
3/27/2013
- CFPB Debt Collection Dodd-Frank FDCPA FTC
It seems two major auto dealer trade groups share my doubts about whether the CFPB’s position on dealer rate participation will really help car buyers. In a statement responding to CFPB Bulletin 2013-02, the National...more
3/25/2013
- Car Dealerships CFPB Financing FTC
The Consumer Financial Protection Bureau has issued a proposal to supervise nonbank servicers of private and federal student loans who qualify as “larger participants” in the student loan servicing market. Comments on the...more
3/19/2013
- CFPB Dodd-Frank Servicing Policies Student Loans
Not only did the Senate Banking Committee hearing this morning on Richard Cordray’s nomination to be CFPB Director produce no fireworks, there were moments when Committee members seemed to forget he was in the hearing room....more
3/13/2013
- CFPB Nominations Richard Cordray
The CFPB’s practice of bringing enforcement attorneys to examinations has been a continuing concern for industry. In particular, supervised entities worry that the participation of enforcement attorneys in examinations...more
3/6/2013
- CFPB Enforcement Attorneys Industry Examinations OIG
President Obama’s renomination of Richard Cordray to serve as CFPB Director is now official. On February 13, the White House announced that his nomination was sent to the Senate....more
2/15/2013
- Barack Obama CFPB Nominations Richard Cordray
