The CFPB recently updated its examination manual to, in Director Chopra’s words, “combat discriminatory practices across the board in consumer finance.” Under the CFPB’s revised manual, any discriminatory conduct that the...more
7/22/2022
/ Anti-Discrimination Policies ,
Banking Examinations ,
Compliance ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
ECOA ,
Examination Manual ,
Fair Housing Act (FHA) ,
Financial Services Industry ,
FinTech ,
Marketing ,
UDAAP ,
Unfair or Deceptive Trade Practices
Under the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank), the Consumer Financial Protection Bureau (CFPB) has authority to require reports and conduct examinations with respect to large...more
5/9/2022
/ Comment Period ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Protection Laws ,
Dodd-Frank ,
ECOA ,
Enforcement Authority ,
Financial Services Industry ,
FinTech ,
Nonbank Firms ,
Proposed Rules ,
Regulatory Authority
In December 2019, PayPal, Inc. filed suit in the US District Court for the District of Columbia challenging the CFPB’s authority to issue two provisions of the so-called prepaid rule, which governs consumer financial products...more
5/9/2022
/ Chevron Deference ,
Consumer Financial Protection Bureau (CFPB) ,
Digital Wallets ,
Disclosure Requirements ,
Dodd-Frank ,
ECOA ,
EFTA ,
Fair Credit Reporting Act (FCRA) ,
Financial Services Industry ,
Lack of Authority ,
PayPal ,
Prepaid Payment Products ,
Truth in Lending Act (TILA)
On September 1, 2021, the CFPB issued a proposed rule that would add a new subpart to Regulation B, which implements the federal Equal Credit Opportunity Act (ECOA). The rule would implement Section 1071 of the Dodd-Frank Act...more
10/22/2021
/ Annual Reports ,
Biden Administration ,
Commercial Loans ,
Consumer Financial Protection Bureau (CFPB) ,
Covered Entities ,
Data Collection ,
Dodd-Frank ,
ECOA ,
Financial Institutions ,
Financial Services Industry ,
Loan Applications ,
Minority-Owned Businesses ,
Proposed Rules ,
Small Business ,
Women-Owned Businesses
In September 2021, the CFPB took action against Better Future Forward, Inc. (BFF), a provider of student income share arrangements, and LendUp, an online, subprime consumer lender. In both cases, the CFPB alleged that the...more
10/22/2021
/ Consent Order ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Dodd-Frank ,
ECOA ,
Enforcement Actions ,
Financial Services Industry ,
Income Share Agreements ,
Student Loans ,
Subprime Loans ,
Unfair or Deceptive Trade Practices