Timothy S. Crisp

Timothy S. Crisp

Foley & Lardner LLP

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Truth in Lending Act and Consumer Leasing Act Dollar Thresholds Raised: Fewer Transactions Exempt

More consumer credit and leasing transactions will be subject to the Truth in Lending Act (TILA) and Consumer Leasing Act (CLA) in 2015. Effective January 1, 2015, the dollar threshold for exemption of most consumer...more

9/12/2014 - CLA Dodd-Frank Exemptions Regulation M Regulation Z TILA

Credit Card Issuers Beware: CFPB Fires Warning Shot on Promotional APRs

Who could possibly object to zero or low promotional interest rates offered for convenience checks, balance transfers or new purchases? The Consumer Financial Protection Board (CFPB), that’s who....more

9/4/2014 - Banking Sector Banks CFPB Credit Cards Dodd-Frank Interest Rates

Federal Reserve Board Proposes to Repeal Its Regulation AA (Unfair Credit Practices)

The Board of Governors of the Federal Reserve System is requesting comment on its proposal to repeal its Regulation AA, which for nearly 30 years has prohibited banks from engaging in specified unfair and deceptive credit...more

8/26/2014 - Banks Dodd-Frank Federal Reserve FTC Regulation AA Repeal UDAAP Unfair or Deceptive Trade Practices

Remedies Against Receiver Must Be Exhausted Before Claim Against Assignee

The U.S. Court of Appeals for the Ninth Circuit affirmed the dismissal of claims brought by singer-songwriter Todd Rundgren and his wife Michelle Rundgren against JPMorgan Chase Bank, N.A. (Chase). Since the Rundgrens’ claims...more

8/7/2014 - Banks FDIC FIRREA JPMorgan Chase Loans Popular TILA

CFPB Proposes Public Disclosure of Consumer Complaint Narratives

Will the CFPB start disclosing consumers’ gripes and rants? Would it provide endless hours of salacious reading, like complaints posted on popular online review sites like Yelp and Angie’s List? Could it become a platform for...more

7/18/2014 - CFPB Disclosure Requirements

Statements Rendered Credit Report Reseller a Credit Repair Organization

Sounding a cautionary note to the hypercompetitive credit report resale and monitoring industry, the U.S. Court of Appeals for the Ninth Circuit recently held that a reseller’s statements on its website and in television...more

2/25/2014 - Credit Reports CROA

CFPB Finalizes Rule on Awards of Expenses, Attorney Fees to Prevailing Parties in Adversary Proceedings

As previously noted on this blog, the Consumer Financial Protection Bureau (CFPB) issued an interim final rule in June 2012 to implement the Equal Access to Justice Act. At the time, the CFPB requested public comment on the...more

2/14/2014 - Attorney's Fees CFPB Equal Access to Justice Act Final Rules Litigation Fees & Costs

CFPB Prepares to Overhaul Home Mortgage Disclosure Act Rules

The Consumer Financial Protection Bureau (CFPB) is preparing to make significant revisions to the regulations promulgated under the Home Mortgage Disclosure Act of 1975 (HMDA) (Regulation C) by requiring home mortgage lenders...more

2/11/2014 - CFPB Dodd-Frank HMDA Mortgages

Fourth Circuit Lets Consumers Orally Dispute Validity of Debts

In a per curiam decision which vacated the lower court’s dismissal of a consumer class action under the federal Fair Debt Collection Practices Act (FDCPA), the U.S. Court of Appeals for the Fourth Circuit, in a case of first...more

2/4/2014 - Debt Debt Collection FDCPA Written Notice

CFPB Proposes New “Larger Participants” Rule for Non-Bank International Money Transmitters

The Consumer Financial Protection Bureau (CFPB) has proposed a new rule to define “larger participants” of the market for non-bank international money transfers. Comments to the proposed rule will be accepted by the CFPB for...more

1/28/2014 - Banks CFPB Cross-Border Larger Participant Money Transfer Nonbank Firms

Hanging Out to Air: CFPB Expands Consumer Complaint Database

The Consumer Financial Protection Bureau (CFPB) recently expanded its existing Consumer Complaint Database to cover additional consumer financial products and services. ...more

4/12/2013 - CFPB Consumer Complaint System Consumer Reporting Act Financial Products

CFPB Powers Could Be Invalidated Following Ruling on NLRB Recess Appointments

On January 25, 2013, the U.S. Court of Appeals for the D.C. Circuit ruled that President Obama’s purported “recess appointments” to the NLRB last year are constitutionally invalid....more

1/29/2013 - Barack Obama Canning v NLRB CFPB NLRB Political Appointments Pro Forma Sessions Recess Appointments Richard Cordray

Cordray Renominated as Bureau’s Director, But Court Ruling Jeopardizes His Recess Appointment and Bureau’s Powers

It’s been the best of times and the worst of times for Richard Cordray this week. First, President Obama renominated Cordray to be the Consumer Financial Protection Bureau’s (the Bureau) director on January 24, 2013....more

1/28/2013 - Barack Obama Canning v NLRB CFPB NLRB Pro Forma Sessions Recess Appointments Richard Cordray

Chicago Joins CFPB in Information-Sharing Partnership; City Takes Additional Measures

In a first-of-its-kind partnership with a municipality, CFPB Director Richard Cordray and Chicago Mayor Rahm Emanuel jointly announced a framework for sharing of information between the City and the CFPB....more

12/7/2012 - CFPB

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