In This Issue:

Bureau Report; Operations Report; Beltway Report; Arbitration Report; Mortgage Report; Privacy Report; Preemption Report; and Plastics Report.

Excerpt from the Bureau Report:

World’s Most Expensive Blue Sky -

On October 1, 2012, the CFPB brought its third major enforcement action against three American Express subsidiaries (“American Express”), requiring American Express to return $85 million to customers and pay approximately $14 million to the CFPB’s civil money penalty fund, with another $14 million in penalties to other regulators.

The CFPB and other regulators alleged that American Express misled certain new account holders by stating that they would receive $300 when signing up for the Blue Sky credit card and satisfying other terms of the offer. American Express was also alleged to have (1) inappropriately used age as a factor in making credit decisions for applicants over the age of 35, (2) charged certain consumers late fees and interest in violation of the Truth in Lending Act (“TILA”), (3) failed to report that information was disputed by consumers when the information was furnished to credit bureaus, and (4) engaged in deceptive debt collection practices.

Please see full issue 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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