“Although there may be other constitutional checks on Congress’ authority to create and fund an administrative agency, specifying the source and purpose is all the control the Appropriations Clause requires.” With these...more
As we all hit the grocery store for that forgotten cranberry sauce and send a few last urgent work emails, we hope everyone is able to be with friends and family this Thanksgiving. Here at Bradley, we are counting our...more
On February 28, 2022, the CFPB released a Compliance Bulletin and policy guidance entitled “Mitigating Harm from Repossession of Automobiles.” In its bulletin, the CFPB sets forth the objective of reminding market...more
Last November, Bradley’s Financial Services Perspectives team predicted that the Consumer Financial Protection Bureau’s (CFPB) then upcoming Notice of Proposed Rulemaking (NPRM) for the Does the New Debt Collection Rule Apply...more
6/14/2019
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Creditors ,
Debt Collection ,
Debt Collectors ,
Dodd-Frank ,
Enforcement ,
Enforcement Authority ,
FDCPA ,
NPRM ,
Proposed Rules ,
UDAAP
In 2013, the Consumer Financial Protection Bureau (CFPB) issued a bulletin on indirect auto lending that took the industry by storm. As we approach the five-year anniversary of the memo’s issuance, it’s valuable to reflect on...more
1/25/2018
/ Automotive Industry ,
Automotive Loans ,
Congressional Review Act ,
Consumer Financial Contracts ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Discrimination ,
Dodd-Frank ,
GAO ,
Lenders ,
Markups ,
Unfair or Deceptive Trade Practices
Auto lenders, like many private citizens, began 2017 curious as to what change the impending Trump administration would bring. In the landscape of government enforcement, however, the consensus amongst industry participants...more
1/22/2018
/ Automotive Industry ,
Automotive Loans ,
Car Dealerships ,
Congressional Review Act ,
Consumer Financial Contracts ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Dodd-Frank ,
Fair Credit Reporting Act (FCRA) ,
GAO ,
Lenders ,
Markups ,
RESPA ,
Subprime Loans ,
Trump Administration ,
Truth in Lending Act (TILA) ,
Unfair or Deceptive Trade Practices