Financial Services Report – Spring 2019

EDITOR’S NOTE -

In the words of Willie Wonka: “Wait a minute — strike that, reverse it!” As loyal readers will recall, in our last issue, we tried to stay current in referring to the CFPB by what Mick Mulvaney declared would be its new name: the Bureau of Consumer Financial Protection. Well, what a difference a director makes. Shortly after Kathy Kraninger was confirmed by the Senate as the second Director of the agency, she scrapped the name change. We’ll wait to see what happens to the big “bcfp” sign in the lobby of the CFPB’s headquarters! Since Kraninger was confirmed we’ve seen the Bureau issue its first consent orders since former Director Cordray resigned. CFPB-watchers have noted that only one of these consent orders included restitution. A change in direction? A sub rosa recognition of self-reporting and self-remediation? We’ll have to wait and see.

This quarter also brought an about-face by the CFPB on part of the controversial small-dollar loan rule. Consumer advocates and industry trade groups alike are threatening suit on different parts of the proposed rule. Does that indicate it’s a good compromise? Again, we’ll have to wait and see.

Please see full publication below for more information.

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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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