In a June 28 letter to Director Chopra and accompanying White Paper and press release, the ABA, CBA, ICBA, and the U.S. Chamber of Commerce have called on the Consumer Financial Protection Bureau (CFPB or Bureau) to rescind...more
Section 1473(q) of the Dodd-Frank Act (now codified at 12 U.S.C. § 3354(q)) amended the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (“FIRREA”) to instruct the CFPB, Fed, OCC, FDIC, NCUA, and FHFA...more
On January 18, after approximately fourteen months of settlement negotiations, the CFPB announced that it secured a settlement agreement with BrightSpeed Solutions, Inc., a third-party payment processor that had ceased...more
1/20/2022
/ Consumer Financial Protection Bureau (CFPB) ,
Consumer Fraud ,
Covered Person ,
Dodd-Frank ,
Enforcement Actions ,
Financial Distress ,
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Merchants ,
Payment Processors ,
Settlement Agreements ,
Statute of Limitations
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
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
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
A&B ABstract: The CFPB has recently asserted extraordinary authority to make any payment processor monitor the activities of any merchant for which it processes payments, even if that merchant does not provide consumer...more
A&B ABstract: The CFPB’s Bulletin 2021-01 released on March 31, 2021 announced changes to the Bureaus type of communications. Does this bulletin suggest a desire of the CFPB to use the examination process for purposes that...more
Our Financial Services & Products Group explores the case law and academic research surrounding the implications of a President removing a Senate-confirmed department head before the end of their term....more