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Did the CFPB Have Authority to Issue its RFI Regarding Employer-Driven Debt?

A&B Abstract - The CFPB’s statutory authority to issue a recent request for information (RFI) regarding employer-driven debt is in doubt, which may affect the utility of any comments submitted in response to its request....more

One Person’s Junk Fee Is Another’s Treasure

The Consumer Financial Protection Bureau has sought comments on how it can best crack down on what it calls “junk fees.” Our Financial Services & Products Group examines how mortgage servicing is singled out and why mortgage...more

Update Regarding the CFPB’s Buy Now, Pay Later Orders

In a prior post, we reported that the language used in orders recently issued by the CFPB to leading Buy Now, Pay Later (“BNPL”) providers suggested that the CFPB intends to use the information it collects to build...more

Is the CFPB using its market monitoring orders to build enforcement cases?

As we previously noted, on October 21, the CFPB issued orders to six large technology firms seeking information about their payment product business plans (the “October 21 Orders”). According to the Bureau, the purpose of...more

Did the CFPB Follow PRA Requirements in Issuing its Big Tech Orders?

On October 21, the CFPB issued a series of orders to “collect information on the business practices of large technology companies operating payments systems in the United States.”...more

Payday Lending: A Juxtaposition of Recent CFPB Actions

A&B ABstract: Three recent actions by the Consumer Financial Protection Bureau (“CFPB”), on consecutive days, highlights inconsistencies in the CFPB’s current approach to payday lending....more

Key Takeaways from Chopra’s Nomination Hearing

A&B ABstract: On Tuesday, March 2, the Senate Committee on Banking, Housing, and Urban Affairs convened a remote hearing to consider the nominations of Rohit Chopra to be Director of the Bureau of Consumer Financial...more

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