In a move that could significantly impact the auto retail industry, California has introduced Senate Bill 766, known as the California Combating Auto Retail Scams (CARS) Act. Introduced by Senator Benjamin Allen (D) on...more
2/28/2025
/ Automotive Industry ,
California ,
Car Dealerships ,
CARS Rule ,
Consumer Financial Protection Bureau (CFPB) ,
Disclosure Requirements ,
Federal Trade Commission (FTC) ,
Motor Vehicles ,
Proposed Legislation ,
Recordkeeping Requirements ,
Regulation ,
Regulatory Requirements ,
Unfair or Deceptive Trade Practices
In this episode of The Consumer Finance Podcast, Chris Willis is joined by Jason Manning and Joe DeFazio, partners in Troutman Pepper Locke’s Consumer Financial Services practice group. They provide crucial updates on two...more
In this special joint edition of the Consumer Finance Podcast and the Regulatory Oversight Podcast, host Chris Willis is joined by colleagues Stephen Piepgrass, James Kim, Jesse Silverman, and Lane Page to discuss the ongoing...more
In this special joint edition of the Consumer Finance Podcast and the Regulatory Oversight Podcast, host Chris Willis is joined by colleagues Stephen Piepgrass, James Kim, Jesse Silverman, and Lane Page to discuss the ongoing...more
As discussed here, on February 9, the National Treasury Employees Union (NTEU), which includes members employed by the Consumer Financial Protection Bureau (CFPB or Bureau), filed a lawsuit in the District Court for the...more
We are pleased to share our annual review of regulatory and legal developments in the consumer financial services industry. With active federal and state legislatures, consumer financial services providers faced a challenging...more
2/17/2025
/ Automotive Loans ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Enforcement Actions ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinTech ,
Regulatory Agenda ,
Regulatory Requirements ,
TCPA ,
UDAAP ,
Uniform Commercial Code (UCC)
On February 11, President Donald Trump nominated Jonathan McKernan to be the new Director of the Consumer Financial Protection Bureau (CFPB or Bureau). If confirmed by the Senate, McKernan will replace Acting CFPB Director...more
2/13/2025
/ Administrative Appointments ,
Consumer Financial Protection Bureau (CFPB) ,
Enforcement ,
FDIC ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Nominations ,
Regulatory Agencies ,
Regulatory Agenda ,
Regulatory Reform ,
Trump Administration
In this episode of The Consumer Finance Podcast, Chris Willis is joined by Mary Zinsner and Heryka Knoespel, partners in Troutman Pepper Locke’s Consumer Financial Services Practice Group, to discuss the latest in deposit...more
Today, the U.S. District Court for the Northern District of Texas issued an order in Chamber of Commerce of the United States of America v. Consumer Financial Protection Bureau (CFPB or Bureau) in light of recent changes...more
2/11/2025
/ Administrative Procedure Act ,
CARD Act ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Cards ,
Enforcement Actions ,
Final Rules ,
Financial Regulatory Reform ,
Late Fees ,
Preliminary Injunctions ,
Regulatory Requirements ,
Rulemaking Process
On Friday, the U.S. Court of Appeals for the Fifth Circuit ordered the tolling of compliance deadlines for the Consumer Financial Protection Bureau’s (CFPB or Bureau) Small Business Lending Data Collection final rule under...more
In a dramatic series of events, the Consumer Financial Protection Bureau (CFPB or Bureau) has undergone leadership changes, signaling a significant shift in its regulatory approach. These changes began with the firing of...more
2/11/2025
/ Administrative Appointments ,
Constitutional Challenges ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Dodd-Frank ,
Financial Regulatory Reform ,
Financial Services Industry ,
Regulatory Agencies ,
Regulatory Agenda ,
Regulatory Reform ,
Trump Administration
In this third episode of the Year in Review series of The Consumer Finance Podcast, host Chris Willis is joined by Lori Sommerfield, a partner in Troutman Pepper Locke’s Consumer Financial Services Practice Group, to discuss...more
On February 4, Senators Bernie Sanders (I-Vt.) and Josh Hawley (R-Mo.) introduced bipartisan legislation aimed at immediately capping credit card interest rates at 10% for a period of five years. This initiative follows a...more
Hours before a scheduled hearing yesterday, the Consumer Financial Protection Bureau (CFPB or Bureau) filed an “Emergency Notice” in the U.S. Court of Appeals for the Fifth Circuit with respect to the ongoing litigation...more
2/4/2025
/ Administrative Procedure Act ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Data Collection ,
Dodd-Frank ,
Enforcement Actions ,
Final Rules ,
Financial Services Industry ,
Lending ,
Regulatory Requirements ,
Rulemaking Process ,
Section 1071 ,
Small Business ,
Small Business Loans ,
UDAAP
In a significant and highly anticipated move, President Donald Trump has fired Rohit Chopra, the Director of the Consumer Financial Protection Bureau (CFPB or Bureau). Rohit Chopra, who had been serving as the Director of the...more
In this episode of The Consumer Finance Podcast, host Chris Willis is joined by James Kim and Jesse Silverman, co-leaders of Troutman Pepper Locke’s fintech industry group. They discuss the current regulatory environment for...more
Yesterday, the U.S. Court of Appeals for the Fifth Circuit issued a significant opinion vacating the Federal Trade Commission’s (FTC) Combating Auto Retail Scams Trade Regulation Rule (CARS Rule). The decision came in...more
1/28/2025
/ Administrative Procedure Act ,
Advanced Notice of Proposed Rulemaking (ANPRM) ,
Appeals ,
Arbitrary and Capricious ,
Automotive Industry ,
Car Dealerships ,
CARS Rule ,
Federal Trade Commission (FTC) ,
Final Rules ,
FTC Act ,
Motor Vehicles ,
Regulatory Requirements ,
Rulemaking Process ,
Statutory Interpretation ,
Unfair or Deceptive Trade Practices ,
Vacated
In this episode of The Consumer Finance Podcast, host Chris Willis and Michael Lacy, Consumer Financial Services Practice Group leader, introduce Troutman Pepper Locke's annual Year in Review and Look Ahead publication. The...more
Earlier this month, the Consumer Financial Protection Bureau (CFPB or Bureau) issued new policy statements regarding its Compliance Assistance Sandbox (CAS) and No-Action Letters (NAL) programs. ...more
1/24/2025
/ Competition ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Enforcement Actions ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Innovation ,
No-Action Letters ,
Regulatory Agenda ,
Regulatory Oversight ,
Sandbox ,
Supervision ,
Transparency
Last week, the Consumer Financial Protection Bureau (CFPB or Bureau) released its latest Supervisory Highlights report, focusing on the use of advanced technologies in credit scoring models. ...more
1/22/2025
/ Artificial Intelligence ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Scores ,
Data Privacy ,
Data Protection ,
Discriminatory Lending Practices ,
ECOA ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
Machine Learning ,
Regulatory Requirements ,
Risk Management
On January 15, the Consumer Financial Protection Bureau (CFPB or Bureau) released a blog post highlighting the growing efforts by financial institutions to serve consumers with limited English proficiency (LEP). However,...more
In this episode of The Consumer Finance Podcast, host Chris Willis and guest Joe Reilly delve into recent CFPB consent orders that penalize financial services companies for allegedly launching products before they were fully...more
As the Consumer Financial Protection Bureau (CFPB or Bureau) anticipates a shift in its leadership with the incoming administration of President Trump, the Bureau has released a report titled “Strengthening State-Level...more
1/16/2025
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Privacy Rights ,
Data Privacy ,
Enforcement Actions ,
Federal v State Law Application ,
Financial Regulatory Reform ,
Financial Services Industry ,
Hidden Fees ,
New Legislation ,
Regulatory Agenda ,
Trump Administration
On January 13, the Consumer Financial Protection Bureau (CFPB or Bureau) released a report providing its analysis of the growth and impact of Buy Now, Pay Later (BNPL) loans in the United States since 2019. BNPL loans,...more
The Consumer Financial Protection Bureau (CFPB or Bureau) proposed a new rule aimed at banning certain contractual provisions in agreements for consumer financial products or services. The CFPB’s proposal targets certain...more
1/15/2025
/ Arbitration Agreements ,
Comment Period ,
Consumer Financial Contracts ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Contract Terms ,
Federal Trade Commission (FTC) ,
Financial Regulatory Reform ,
Proposed Rules ,
Public Comment ,
Regulatory Agenda ,
Small Business ,
Unfair or Deceptive Trade Practices