The Consumer Financial Protection Bureau (CFPB or Bureau) has issued a new proposed rule that would substantially revise the 2023 small business lending data collection and reporting rule under the Equal Credit Opportunity...more
11/13/2025
/ Compliance Dates ,
Consumer Financial Protection Bureau (CFPB) ,
Data Collection ,
Department of Justice (DOJ) ,
Dodd-Frank ,
ECOA ,
Lenders ,
Loans ,
Notice of Proposed Rulemaking (NOPR) ,
Proposed Rules ,
Reporting Requirements ,
Section 1071 ,
Small Business
The Consumer Financial Protection Bureau (CFPB or Bureau) has proposed an unprecedented, far‑reaching rewrite of Regulation B (Reg B) under the Equal Credit Opportunity Act (ECOA). If finalized, the proposed rule would...more
11/13/2025
/ Comment Period ,
Constitutional Challenges ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Protection Laws ,
Creditors ,
Disparate Impact ,
ECOA ,
Executive Orders ,
Fair Lending ,
Notice of Proposed Rulemaking (NOPR) ,
Proposed Rules ,
Regulation B ,
Rulemaking Process ,
Special Purpose Credit Programs ,
Statutory Interpretation
This week, the U.S. Department of Justice (DOJ) notified the U.S. District Court for the District of Columbia and the D.C. Circuit in the matter of National Treasury Employees Union v. Vought that the Consumer Financial...more
11/12/2025
/ Appropriations Bill ,
Consumer Financial Protection Bureau (CFPB) ,
Department of Justice (DOJ) ,
Dodd-Frank ,
Enforcement ,
Federal Funding ,
Federal Reserve ,
Government Agencies ,
Regulatory Authority ,
Reporting Requirements ,
Statutory Interpretation ,
Supervision
At The Clearing House Annual Conference, Comptroller of the Currency Jonathan Gould outlined an agency-wide strategy to defend and promote federal preemption across the banking system. As reported by Law360, he emphasized...more
On October 29, the Consumer Financial Protection Bureau (CFPB or Bureau) officially rescinded its rule requiring nonbank entities to register certain agency and court orders with the Bureau. This decision follows a proposal...more
11/3/2025
/ Consumer Financial Protection Bureau (CFPB) ,
Deregulation ,
Final Rules ,
Financial Regulatory Reform ,
Financial Services Industry ,
Nonbank Firms ,
Regulatory Burden ,
Regulatory Oversight ,
Regulatory Reform ,
Regulatory Requirements ,
Reporting Requirements
In this episode of The Consumer Finance Podcast, Chris Willis is joined by colleagues Jason Manning and Carter Nichols to explore the intricacies of the Servicemembers Civil Relief Act (SCRA). As the current administration...more
10/30/2025
/ Active Duty ,
Class Action ,
Consumer Financial Products ,
Consumer Protection Laws ,
Financial Institutions ,
Financial Services Industry ,
Interest Rate Caps ,
Lenders ,
Military Lending Act ,
Pending Litigation ,
Regulatory Requirements ,
Servicemembers Civil Relief Act (SCRA)
On October 28, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a new interpretive rule replacing its 2022 interpretive rule (withdrawn in May 2025) concerning the scope of preemption under the Fair Credit...more
10/29/2025
/ Consumer Financial Protection Bureau (CFPB) ,
Consumer Reports ,
Executive Orders ,
Fair Credit Reporting Act (FCRA) ,
Financial Services Industry ,
Interpretive Rule ,
New Guidance ,
Preemption ,
Regulatory Reform ,
Regulatory Requirements ,
Statutory Interpretation
In this crossover episode of Payments Pros and The Consumer Finance Podcast, Chris Willis, Jason Cover, and Taylor Gess discuss licensed lending and bank model lending programs. This conversation dives into the benefits,...more
In this episode of The Consumer Finance Podcast, Chris Willis is joined by Lori Sommerfield and James Stevens to delve into the implications of President Trump's Executive Order 14331, "Guaranteeing Fair Banking for All...more
On October 2, the Consumer Financial Protection Bureau (CFPB or Bureau) published a final rule in the Federal Register, officially extending compliance dates for its 2023 small business lending data collection and reporting...more
10/7/2025
/ Compliance Dates ,
Consumer Financial Protection Bureau (CFPB) ,
Data Collection ,
Dodd-Frank ,
ECOA ,
Final Rules ,
Regulation B ,
Reporting Requirements ,
Rulemaking Process ,
Section 1071 ,
Small Business
In this crossover episode of The Consumer Finance Podcast and Regulatory Oversight, Chris Willis is joined by Joseph DeFazio, Bill Foley, and Michael Yaghi to discuss the implications of New York's FAIR Act, a significant...more
Recently, the U.S. Department of Housing and Urban Development (HUD) issued two memoranda that clarify HUD’s role in enforcing the Fair Housing Act (FHA), explain how future enforcement efforts will proceed, and officially...more
In this crossover episode of The Consumer Finance Podcast and Regulatory Oversight, Chris Willis is joined by Joseph DeFazio, Bill Foley, and Michael Yaghi to discuss the implications of New York's FAIR Act, a significant...more
In this episode of The Consumer Finance Podcast, Chris Willis, co-leader of Troutman Pepper Locke’s Consumer Financial Services Regulatory practice, delves into the intricacies of corporate restructuring with Alex Rovira, a...more
On September 8, the Office of the Comptroller of the Currency (OCC) took significant action to “depoliticize” the federal banking system by issuing two bulletins to banks that further the goals of Executive Order 14331...more
9/10/2025
/ Anti-Money Laundering ,
Banks ,
Community Reinvestment Act ,
Data Privacy ,
Enforcement Priorities ,
Financial Institutions ,
Financial Regulatory Reform ,
OCC ,
Regulatory Requirements ,
Risk Management ,
Suspicious Activity Reports (SARs)
On April 16, the Consumer Financial Protection Bureau released a memo to staff outlining its new supervision and enforcement priorities for 2025. These priorities appear to be intended to reverse some of the more prominent...more
9/4/2025
/ Banks ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Deregulation ,
Enforcement Priorities ,
Fair Lending ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Mortgages ,
Nonbank Firms ,
Regulatory Reform ,
Trump Administration
On August 29, the Federal Deposit Insurance Corporation (FDIC) announced updates to its Consumer Compliance Examination Manual, marking a pivotal shift in how potential discrimination under the Equal Credit Opportunity Act...more
9/4/2025
/ Banks ,
Consumer Financial Products ,
Disparate Impact ,
Disparate Treatment ,
ECOA ,
Executive Orders ,
Fair Housing Act (FHA) ,
Fair Lending ,
FDIC ,
Financial Institutions ,
Financial Services Industry ,
Government Agencies ,
Regulatory Reform ,
Trump Administration ,
Unfair or Deceptive Trade Practices
In this episode of The Consumer Finance Podcast, Chris Willis and Louis Manetti delve into the evolving legal landscape surrounding the statute of limitations for mortgage foreclosures in Illinois. With recent cases...more
On August 26, the U.S. Small Business Administration (SBA) took action to enforce President Trump’s directive by issuing a letter to its network of over 5,000 lenders. This letter mandates the cessation of alleged politicized...more
8/29/2025
/ Banks ,
Consumer Financial Products ,
Enforcement Actions ,
Executive Orders ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Lenders ,
Popular ,
Regulatory Requirements ,
Reporting Requirements ,
SBA ,
Small Business Loans ,
Trump Administration
The Consumer Financial Protection Bureau (CFPB or Bureau) is taking a significant step to modify its supervisory approach to nonbanks by publishing a proposed rule advancing a more stringent definition of “risks to consumers”...more
8/29/2025
/ Comment Period ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Financial Regulatory Reform ,
Financial Services Industry ,
Non-Bank Lenders ,
Non-Depository Institutions ,
Proposed Rules ,
Regulatory Agenda ,
Regulatory Oversight ,
Regulatory Reform ,
Risk Management ,
Rulemaking Process ,
Statutory Interpretation ,
Supervision ,
Supervisory Guidance
In this episode of The Consumer Finance Podcast, Chris Willis, Heryka Knoespel, and Lori Sommerfield discuss overdraft and deposit account fees as they continue to dive into the CFPB's guidance withdrawal. They highlight the...more
As has been well-documented, the Consumer Financial Protection Bureau (CFPB or Bureau) is navigating a period of significant uncertainty. Just last week, the U.S. Court of Appeals for the District of Columbia vacated a...more
8/22/2025
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Dodd-Frank ,
ECOA ,
Financial Services Industry ,
Hiring & Firing ,
Layoffs ,
Mortgage Loan Originators ,
Mortgages ,
Open Banking ,
Payday Lending Rule ,
Regulatory Agenda ,
Rulemaking Process ,
Small Business ,
UDAAP
On August 8, the Consumer Financial Protection Bureau (CFPB or Bureau) published a series of proposed rules aimed at redefining what constitutes a “larger participant” in several key financial markets. Under § 1024 of the...more
8/22/2025
/ Automotive Industry ,
Comment Period ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Bureaus ,
Debt Collectors ,
Financial Regulatory Reform ,
Financial Services Industry ,
Money Transfer ,
Non-Bank Lenders ,
Proposed Rules ,
Public Comment ,
Regulatory Agenda ,
Regulatory Oversight ,
Remittance Transfer Rule
On August 15, the U.S. Court of Appeals for the District of Columbia issued a decision in the case of National Treasury Employees Union (NTEU) v. Consumer Financial Protection Bureau (CFPB or Bureau). The appellate court...more
8/18/2025
/ Administrative Procedure Act ,
Appeals ,
Constitutional Challenges ,
Consumer Financial Protection Bureau (CFPB) ,
Dodd-Frank ,
Government Agencies ,
Hiring & Firing ,
Jurisdiction ,
Preliminary Injunctions ,
Regulatory Violations ,
Statutory Interpretation ,
Title X ,
Trump Administration ,
Unions ,
Vacated
In this episode of The Consumer Finance Podcast, Chris Willis is joined by veteran litigators Jason Manning and Carter Nichols to explore litigation implications following the CFPB’s withdrawal of nearly 70 pieces of informal...more