News & Analysis as of

Consumer Financial Protection Bureau (CFPB) Public Comment

Latham & Watkins LLP

CFPB Proposes to Designate Earned Wage Access Products as Loans

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Paycheck advance products that are deemed consumer loans under the CFPB’s new proposal would be subject to increased disclosure and regulatory protections....more

Orrick, Herrington & Sutcliffe LLP

CFPB proposes an interpretive rule for earned wage access

On July 18, the CFPB proposed an interpretive rule to clarify that many paycheck advance products, or "earned wage" products, were consumer loans and therefore subject to TILA. The CFPB seeks to require lenders to provide...more

Troutman Pepper

CFPB Issues Final Rule under Section 1033 Establishing Qualifications for Recognition of Industry Standard Setter Bodies

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Wednesday, the Consumer Financial Protection Bureau (CFPB or Bureau) announced it has finalized a rule outlining the qualifications to become a recognized industry Standard Setter body (Standard Setter Rule). These bodies...more

Troutman Pepper

CFPB Probing Alleged “Junk Fees” in Mortgage Closing Costs

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On May 30, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a request for information (Request) regarding alleged “junk fees” in closing costs charged by mortgage lenders and related settlement service...more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - May 2024

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Nutter McClennen & Fish LLP

Nutter Bank Report: January 2024

OCC Requests Public Comments on Proposed Bank Merger Policy Statement and Rules The OCC has proposed a new policy to increase the transparency of the standards that the agency applies to review business combinations involving...more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - December 2023 # 2

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - November 2023 # 2

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Troutman Pepper

Big Tech in the CFPB’s Crosshairs: Bureau Proposes to Supervise Larger Technology Companies Offering Digital Wallets and Payment...

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On November 7, the Consumer Financial Protection Bureau (CFPB) issued a proposed rule with request for public comment to amend existing regulations defining “larger participants” the CFPB supervises by adding a new section to...more

Troutman Pepper

Biden-Harris Administration Amends Higher Education Act to Address College Closures and Withholding Transcripts

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On October 24, the Biden-Harris administration announced amendments to the regulations implementing title IV of the Higher Education Act of 1965 (HEA). According to the fact sheet, the amendments are intended to allow the...more

Venable LLP

FTC Releases Proposed Rule Targeting "Junk" Fees

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This week, the Federal Trade Commission (FTC) released a Proposed Rule, “Rule on Unfair or Deceptive Fees.” The Proposed Rule comes after the FTC solicited comments through its Advance Notice of Proposed Rulemaking in...more

Venable LLP

FTC Releases Proposed Rule Targeting “Junk” Fees

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This week, the Federal Trade Commission (FTC) released a Proposed Rule, “Rule on Unfair or Deceptive Fees.” The Proposed Rule comes after the FTC solicited comments through its Advance Notice of Proposed Rulemaking in...more

Troutman Pepper

CFPB Will Seek Public Input on Proposed Rule on Mandatory Pre-Dispute Arbitration Provisions

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In response to a petition filed last week by a number of consumer advocacy groups, the Consumer Financial Protection Bureau (CFPB or Bureau) announced that it will be seeking public input on a possible rule that would curtail...more

Ballard Spahr LLP

FTC requests comment on consumer advocate petition regarding auto “yo-yo financing”

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On May 31, 2023, the Federal Trade Commission (“FTC”) requested public comment on a petition for rulemaking it received from six national consumer advocate groups regarding “yo-yo sales,” a term the groups use to refer to...more

Orrick, Herrington & Sutcliffe LLP

FSOC seeks feedback on proposed analytic framework for financial stability risks, guidance on nonbank determinations

On April 21, the Financial Stability Oversight Council (FSOC) released a proposed analytic framework for financial stability risks, “intended to provide greater transparency to the public about how [FSOC] identifies,...more

Cadwalader, Wickersham & Taft LLP

CFPB Seeks Comments Regarding the Collection and Sale of Consumer Information by Data Brokers

Earlier this month, the CFPB issued a press release and a Request for Information (“RFI”) that is focused upon whether the CFPB should promulgate additional rules implementing the Fair Credit Reporting Act....more

Sheppard Mullin Richter & Hampton LLP

CFPB, FTC Seek Public Comment on Tenant Background Checks

On February 28, 2023, the FTC and the CFPB issued a joint request for information (“RFI”) seeking public comment on background checks used to screen potential tenants for rental housing...more

Troutman Pepper

Public Comments on the CFPB’s Proposed Section 1033 Data Access Rule

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As discussed here, on October 27, 2022, the CFPB released an Outline of Proposals and Alternatives Under Consideration for public comments on the CFPB’s Section 1033 rulemaking. The window for providing written feedback...more

Perkins Coie

Fintech Legal Report - January 2023

Perkins Coie on

CFPB Seeks Public Input on Consumer Credit Card Market - On January 24, the Consumer Financial Protection Bureau (CFPB) issued a request for information seeking public feedback on how the consumer credit market is...more

Troutman Pepper

CFPB Moves Forward With Proposed Rule Establishing Public Registry of Terms and Conditions in Form Contracts

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As forecasted in its 2022 Fall Rulemaking Agenda discussed here, today the Consumer Financial Protection Bureau (CFPB) published a proposed rule with request for public comments that would require certain nonbank covered...more

Miles & Stockbridge P.C.

CFPB Considers Whether TILA Preempts State Commercial Finance Disclosure Laws, Requests Public Comment

A number of states have enacted laws requiring consumer-like disclosures in certain commercial financing transactions. These state statutes resemble the Truth in Lending Act (TILA) in certain respects but apply only to...more

Brownstein Hyatt Farber Schreck

CFPB Invites Comments on Proposed Registry of Nonbank Financial Firms

Seeking to “enhance market monitoring and risk-based supervision efforts,” the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) has proposed a new, online registry of nonbank financial firms in order to track, what...more

Cooley LLP

CFPB Proposes Public Enforcement Order Registry for Nonbank Financial Services Providers

Cooley LLP on

On December 12, 2022, the Consumer Financial Protection Bureau published a proposed rule that would require nonbank covered persons to report certain public agency enforcement actions and court orders for publication in a...more

Goodwin

Federal Reserve Invites Public Comment on Proposed Principles for Large Banking Organizations to Manage Climate-Related Financial...

Goodwin on

Regulatory Developments - Federal Reserve Invites Public Comment on Proposed Principles for Large Banking Organizations to Manage Climate-Related Financial Risks - On December 2, the Federal Reserve announced that it...more

Nutter McClennen & Fish LLP

Nutter Bank Report: November 2022

Headlines: CFPB Reminds Credit Bureaus and Furnishers of Their Obligations to Investigate Disputes The CFPB has issued guidance on the obligations of both credit bureaus and furnishers of consumer credit information,...more

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