Consumer Financial Protection Bureau: Fall 2012 Quarterly Update

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The beat (cop) goes on. Since the Consumer Finance Protection Bureau's (CFPB) first enforcement action on July 18, 2012 ordering Capital One to pay $210 million for deceptive marketing tactics, the CFPB has dominated headlines for similar actions against Discover Bank, and American Express totaling $313 million. Headlines, however, are just the tip of the iceberg. Which is why the Brownstein Hyatt Farber Schreck, LLP CFPB Task Force focuses on what is driving the headlines. We are constantly watching the enforcement probes, the court filings, and the proposed rule making. This quarterly update will address some of the most significant recent developments:

Increased Number of Complaints -

Between July 2011 and September 2012, approximately 79,200 complaints were submitted to the CFPB (including more than 33,570 since June 1, 2012). Eighty-two percent of these complaints had been sent by Consumer Response to the complained of "Companies" for their review; 10 percent were referred to other regulatory agencies and the remaining eight percent were either found to be incomplete or were pending with the consumer or the CFPB. According to published statistics, Companies have responded to 94 percent of the complaints sent to them for a response. Twenty-one percent of the Companies' responses have been disputed by consumers. As previously reported, it is important to note that the CFPB's investigators are prioritizing complaints where the Companies miss the response deadlines.

Please see full update below for more information.

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Published In: Administrative Agency Updates, General Business Updates, Communications & Media Updates, Consumer Protection Updates, Finance & Banking Updates

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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