Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more
On October 25, for the sixth time since its inception, the Consumer Financial Protection Bureau ("CFPB" or "Bureau") released its biennial report ("Report") evaluating the state of the consumer credit card market. The Credit...more
Perhaps not as prominent in the national news as another relatively high-profile balloon, in its latest effort to legislate and regulate by enforcement, the Consumer Financial Protection Bureau (CFPB), together with New...more
The CFPB issued market-monitoring orders under the Dodd-Frank Wall Street Reform and Consumer Protection Act to five companies offering “buy now, pay later” credit requiring them to provide information for its examination of...more
At the end of last week, the CFPB sent orders to five companies that offer buy-now-pay-later (BNPL) products directing them to provide information to the Bureau. The orders were issued as market monitoring orders under the...more
Things are quickly changing at the Consumer Financial Protection Bureau. President Joe Biden made Dave Uejio acting director of the CFPB on January 20, and nominated former FTC Commissioner Rohit Chopra for director... ...more
The CFPB has issued its long-awaited final rule rescinding the ability-to-repay provisions in its final payday/auto title/high-rate installment loan rule (Payday Rule). The final rule will be effective 90 days after its...more
The Consumer Financial Protection Bureau (CFPB) issued its final rule on payday, vehicle title, and certain high-cost installment loans. The new rule is effective in 2019 and imposes stringent underwriting requirements and...more
On June 2, 2016, the Consumer Financial Protection Bureau released its long-anticipated notice of proposed rulemaking on short-term consumer lending. The proposed rule follows the CFPB’s March 2015 release of an outline of...more
As expected, the CFPB issued its proposed payday loan rule, in a release running 1,334 pages. The CFPB also issued a fact sheet summarizing the proposal. Once we complete our initial review of the proposal, we will issue a...more
In addition to the proposed payday loan rule released yesterday, the CFPB has issued (1) a “Request for Information on Payday Loans, Vehicle Title Loans, Installment Loans, and Open-End Lines of Credit,” and (2) a report...more
Wednesday, I had the opportunity to participate as an advisor to a small entity representative (“SER”) at the small business review panel on payday, title and installment loans. The meeting was held in the Treasury Building’s...more
Since last March, when the CFPB issued Bulletin No. 2013-02, its highly controversial release warning banks and finance companies that purchase motor vehicle installment sales contracts that, under existing law, any dealer...more