The CFPB continues to flex its muscle and expand its reach, this time punishing a prepaid card provider and its vendor for a conversion to a new system that did not go as planned. The consent order, which was entered into...more
The CFPB recently entered into consent orders with several Citibank subsidiaries attacking their mortgage servicing practices during the early days of the Mortgage Servicing Rules despite the CFPB’s assurances that early...more
The CFPB recently issued its third consent order involving a debt collection law firm and appears to be expanding its interpretation of “meaningful involvement”. The order, which was entered against two related debt...more
Marketing practices remain at the forefront of CFPB activity as evidenced by two recent consent orders entered into with TransUnion and Equifax. The consent orders combine to require the CRAs to pay more than $17.6 million...more
1/17/2017
/ Advertising ,
Civil Monetary Penalty ,
Compliance Management Systems ,
Consent Order ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Reporting Agencies ,
Disclosure Requirements ,
Equifax ,
Failure To Disclose ,
Informed Consent ,
Marketing ,
Restitution ,
TransUnion ,
UDAAP
The Department of Justice has entered into a proposed consent order with two Ohio based banks resolving allegations that the banks engaged in a pattern or practice of redlining in their mortgage lending practices by...more
1/4/2017
/ Banks ,
Compliance Management Systems ,
Consent Order ,
Consumer Financial Protection Bureau (CFPB) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Fair Lending ,
HMDA ,
Mortgage Lenders ,
Race Discrimination ,
Redlining
A recent series of CFPB consent orders should remind the mortgage industry to carefully monitor its advertising practices. The MAP Rule prohibits deceptive and misleading commercial communications regarding any term of any...more
12/28/2016
/ Advertising ,
Civil Monetary Penalty ,
Compliance ,
Consent Order ,
Consumer Financial Protection Bureau (CFPB) ,
Document Retention Policies ,
Dodd-Frank ,
Employee Training ,
Enforcement Actions ,
MAP Rule ,
Mortgage Lenders ,
Remediation ,
Reverse Mortgages ,
Unfair or Deceptive Trade Practices