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CFPB Agrees To Eliminate $8 Cap on Credit Card Late Fees

On April 15, 2025, the U.S. District Court for the Northern District of Texas vacated a Consumer Financial Protection Bureau (CFPB) rule that capped credit card late fees at $8....more

2024 Year in Review: Mortgage Origination and Servicing

With the change in administration, enforcement actions at the federal level are expected to decrease, reflecting President Trump’s focus on deregulation. Indeed, during President Trump’s first term, the number of enforcement...more

Portions of New York’s FAPA Survive Constitutional Challenges

Over the last four months, New York’s Appellate Division has finally begun to address constitutional challenges to the state’s Foreclosure Abuse Prevention Act (FAPA), an act that became effective in December 2022 and...more

Constitutionality of Shortened Time Limits on New York Foreclosures Still Unresolved

​​​​​​​On September 12, 2024, New York’s highest court dismissed an appeal challenging the constitutionality of the retroactive application of the Foreclosure Abuse Prevention Act (“FAPA”), a law that amended certain New York...more

SCOTUS Ruling Makes Federal Agency Rules Susceptible to Previously Untimely Challenges

​​​​​​​At the close of an extended term, on July 1, 2024, the U.S. Supreme Court expanded the time period for bringing a facial challenge to a federal agency rule....more

CFPB Updates its Procedures for Determining Which Nonbanks it Can Supervise

The Consumer Financial Protection Bureau (CFPB) recently issued a new procedural rule to streamline how it determines which nondepository institutions it has the authority to supervise. According to the CFPB, the new rule...more

Chamber of Commerce Sues CFPB To Eliminate or Enjoin $8 Late Fee Cap

Last week, the U.S. Chamber of Commerce (Chamber) joined five other trade associations to sue the Consumer Financial Protection Bureau (CFPB) and its director Rohit Chopra in Texas Federal District Court, seeking a court...more

2023 Year in Review: Mortgage Origination and Servicing

Welcome to the Mortgage Origination and Servicing chapter of our annual report Consumer Financial Services 2023 Year in Review. Looking Ahead to 2024 - Enforcement efforts are expected to increase in 2024 and will...more

FCC Confirms A.I.-Generated Robocall Voices Are “Artificial” under the TCPA

Last week, the Federal Communications Commission (FCC) released a Declaratory Ruling stating that existing federal regulations related to using “an artificial or prerecorded voice” to deliver a telephone message, also...more

Awaiting Appellate Precedent on Whether Recent New York Foreclosure Limits Are Constitutional

​​​​​​​Over a year after becoming law, New York’s Foreclosure Abuse Prevention Act, L. 2022, ch. 821 (eff. Dec. 30, 2022) (FAPA) continues to divide trial courts regarding the constitutionality of the law’s retroactive...more

“Open Banking” Promoted in New CFPB Rule

​​​​​​​In October 2023, the Consumer Financial Protection Bureau (CFPB) proposed a new rule intended to encourage “open banking”. “Open banking” is a practice of sharing, with consent, consumers’ banking and financial data...more

CFPB Analyzes Mobile Device Tap-To-Pay Market as Possible Precursor to New Regulation

​​​​​​​On September 7, 2023, the Consumer Financial Protection Bureau (CFPB) published its analysis of how smartphone companies are affecting consumers’ use of so-called “tap-to-pay” technology – the wireless transfer of data...more

New York Courts Split on the Constitutionality of the Foreclosure Abuse Prevention Act

In the six months since New York’s governor signed the Foreclosure Abuse Prevention Act, L. 2022, ch. 821 (eff. Dec. 30, 2022) (FAPA), a split has emerged about whether the law applies retroactively....more

Tougher Standards for Certain Home Improvement Loans

On May 1, 2023, the Consumer Financial Protection Bureau (CFPB) issued a report and a proposed rule to clarify and strengthen its regulation of so-called Property Assessed Clean Energy (PACE) financing. PACE financing is...more

FCC Proposes Rules To Block Illegal Text Messages and Close the “Lead Generator Loophole”

​​​​​​​On February 23, 2023, the Federal Communications Commission (FCC) issued a Further Notice of Proposed Rulemaking (FNPRM) seeking public comment on proposed rules targeting unlawful text messages. If the proposed rules...more

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