Nancy R. Thomas

Nancy R. Thomas

Morrison & Foerster LLP

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Strike Two for Alleged L.O. Comp. Violations

Last week, the Bureau announced a $730,000 settlement with Franklin Loan Corporation (Franklin) based on alleged violations of the loan originator compensation rule in Regulation Z. That rule prohibits mortgage lenders from...more

11/19/2014 - CFPB Consent Order Enforcement Actions Mortgage Lenders Mortgage Loan Originators Regulation Z

The CFPB's Most Recent Consent Order: Defining "Abusive" Acts and Practices Through Enforcement

Last week, the CFPB announced a settlement with payday lender ACE Cash Express of an enforcement action for alleged unfair, deceptive, and abusive practices (UDAAP). The Consent Order reflects the CFPB’s continued focus on...more

7/16/2014 - CFPB Enforcement Enforcement Actions Payday Loans UDAAP

Takeaways From GE Capital's $225M Credit Card Settlement

Last week, the Consumer Financial Protection Bureau announced a $225 million settlement of two major credit card enforcement matters with Synchrony Bank, formerly known as GE Capital Retail Bank. First, the “add-on matter”...more

6/27/2014 - Banks CFPB Credit Cards Dodd-Frank Enforcement Actions Settlement UDAAP

CFPB & DOJ Consent Orders with Former GE Capital Retail Bank: Something Old and Something New

Yesterday, the CFPB announced a $225 million settlement of two major credit card enforcement matters with Synchrony Bank, formerly known as GE Capital Retail Bank. First, the “Add-On Matter” targets alleged deceptive...more

6/23/2014 - CFPB Consent Order Debt Collection Discrimination Dodd-Frank DOJ Enforcement Enforcement Actions GE Capital Retail Bank Marketing Racial Discrimination UDAAP Unfair or Deceptive Trade Practices

The CFPB & UDAAP: A “Know It When You See It” Standard?

Institutions regulated by the Consumer Financial Protection Bureau (CFPB) and subject to its enforcement authority are dealing with of the agency’s sweeping authority to prohibit unfair, deceptive, and abusive acts or...more

6/13/2014 - CFPB Enforcement Actions Investigations Richard Cordray UDAAP

The CFPB Targets Mortgage Reinsurance Yet Again

The Consumer Financial Protection Bureau filed an administrative enforcement action against PHH Corporation, alleging a nearly 15-year “mortgage insurance kickback scheme” by its mortgage origination and reinsurance...more

2/4/2014 - CFPB Compliance Enforcement Enforcement Actions Mortgages Reinsurance RESPA TILA

How to Be a Good Corporate Citizen CFPB Style

On June 25, 2013, the Consumer Financial Protection Bureau (CFPB) issued Bulletin 2013-06 identifying “responsible business conduct” that may impact the exercise of its “enforcement discretion.” The Bulletin specifies the...more

7/5/2013 - CFPB Compliance Enforcement Actions Remediation Responsible Business Conduct Self-Policing Self-Reporting

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