Even after the PayPal settlement, the definition of “abusive” remains as subjective and fact specific as ever.
On May 19, PayPal agreed to a $25 million settlement with the Consumer Financial Protection Bureau (CFPB or...more
The most notable items added by the Office of Inspector General (OIG) to its work plan, updated as of July 7, 2014, are audits of the CFPB’s information security program, pay and compensation program, and distribution of...more
The Consumer Financial Protection Bureau (CFPB) recently finalized rules that modified and created specific exemptions to the CFPB’s Ability-to-Repay Rule. The rules have three main effects....more
In its recent decision in J.P. Morgan Securities, Inc. v. Vigilant Ins. Co., 2013 N.Y. LEXIS 1465 (NY June 11, 2013), New York’s Court of Appeals – New York’s highest court – had occasion to consider whether an insured can...more
On April 26, the Consumer Financial Protection Bureau (CFPB or the Bureau) issued a final rule, effective immediately, that sets forth procedures for the administration of the Consumer Financial Civil Penalty Fund (Civil...more
On April 26, the CFPB issued a final rule that (i) establishes the governance structure of the Civil Penalty Fund, including the position of Civil Penalty Fund Administrator, (ii) identifies categories of victims who may...more
In This Issue:
Leading the Past Week; Legislative Branch; and Executive Branch.
Excerpt from Leading the Past Week -
The past week could be best described by one word. Chaos. In the House, a scheduled...more
Last Friday, the CFPB simultaneously issued a final rule to govern the administration of the Bureau’s Civil Penalty Fund (CPF) and proposed revisions to that rule. The final rule is effective immediately upon publication in...more
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