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Eleventh Circuit Judges Question FCC’s One-to-One Consent Rule

On December 18, the U.S. Court of Appeals for the Eleventh Circuit held oral arguments in Insurance Marketing Coalition Limited (IMC) v. Federal Communication Commission (FCC), which challenges the FCC’s December 2023 order...more

FTC Releases Final Junk Fee Rule, Modified to Target Live-Event Tickets and Short-Term Lodging

Today, the Federal Trade Commission (FTC) announced the release of its final Rule on Unfair or Deceptive Fees, also known as the “Junk Fee Rule”, which aims to address so-called bait-and-switch pricing tactics and other...more

2024 Privacy Trends and Their Impact on Auto Finance – Moving the Metal: The Auto Finance Podcast [Audio]

In this episode, Brooke Conkle and Chris Capurso, attorneys in the firm's Consumer Financial Services Practice Group, are joined by Kim Phan, a partner in the firm's Privacy and Cyber Practice Group. They delve into the...more

The CFPB Proposes New FCRA Rule to Dramatically Expand Its Scope, Though Finalization is Unlikely

On December 3, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a proposed rule for public comment aimed at amending Regulation V, which implements the Fair Credit Reporting Act (FCRA). The proposed rule seeks...more

Lemon Law Shakeup: Rodriguez vs. FCA US Has Unexpected Result – Moving The Metal Podcast [Audio]

In this episode, Brooke Conkle and Chris Capurso, attorneys in the firm’s Consumer Financial Services practice, are joined by Partner Ethan Ostroff to discuss the recent Supreme Court of California decision in Rodriguez vs....more

FCC Announces Effective Date for One-to-One Consent Rule

Late last year, we discussed the Federal Communications Commission’s (FCC) new rule aimed at closing the “lead generator” loophole by requiring telemarketers to obtain one-to-one consent from consumers for robocalls and...more

CFPB's Supervisory Highlights on Auto-Finance and Auto-Servicing — Moving the Metal: The Auto Finance Podcast [Audio]

In this special joint episode of The Consumer Finance Podcast and Moving the Metal, Chris Willis teams up with Brooke Conkle and Chris Capurso, hosts of the Moving the Metal podcast, to discuss the CFPB’s recent supervisory...more

CFPB’s Supervisory Highlights on Auto-Finance and Auto-Servicing — The Consumer Finance Podcast [Audio]

In this special joint episode of The Consumer Finance Podcast and Moving the Metal, Chris Willis teams up with Brooke Conkle and Chris Capurso, hosts of the Moving the Metal podcast, to discuss the CFPB’s recent supervisory...more

Breaking Granite: Understanding New Amendments to the New Hampshire Retail Installment Sales Act — Moving the Metal: The Auto... [Audio]

In this episode of Moving the Metal, Chris and Brooke break down recent amendments to the New Hampshire Retail Installment Sales Act. On August 2, New Hampshire Governor Chris Sununu signed HB 1243 into law, bringing...more

Dissecting Oral Arguments in NADA's Challenge to the CARS Rule — Moving the Metal: The Auto Finance Podcast [Audio]

In this podcast episode, Brooke Conkle and Chris Capurso are joined by esteemed senior practitioner Alan Wingfield to discuss the National Automobile Dealer Association’s (NADA) challenge to the Federal Trade Commission’s...more

Federal Agencies Announce Increased Regulations Z and M Dollar Thresholds for Exempt Consumer Credit and Lease Transactions, and...

On October 4, the Consumer Financial Protection Bureau (CFPB) and the Federal Reserve Board (Fed) announced increased dollar thresholds used to determine whether certain consumer credit and lease transactions in 2025 are...more

Effective Dates Announced for Amendments to TCPA Rules

The Federal Communications Commission (FCC) has announced new effective dates for amendments to rules under the Telephone Consumer Protection Act (TCPA) aimed at strengthening consumer protections against robocalls and...more

CFPB’s Fall Edition of Supervisory Highlights Focuses on Auto-Finance Market

On October 7, the Consumer Financial Protection Bureau (CFPB or Bureau) published the Fall edition of its Supervisory Highlights, focusing on examinations of the auto-finance market completed between November 1, 2023, and...more

The CFPB's Report on Negative Equity in Auto Lending — Crossover Episode With Moving the Metal Podcast — The Consumer Finance... [Audio]

In this special crossover episode of The Consumer Finance Podcast and Moving the Metal, Troutman Pepper attorneys Brooke Conkle and Chris Capurso discuss the Consumer Financial Protection Bureau's (CFPB) new report on...more

Investigation Tag Team: The FTC and the State of Arizona — Moving the Metal: The Auto Finance Podcast [Audio]

In this episode, Chris Carlson, an associate in the Regulatory, Investigations, Strategy and Enforcement (RISE) practice, joins Brooke and Chris to discuss how federal and state regulators are collaborating on consumer...more

Seventh Circuit Provides “How To” Successfully Present Consumer Arbitration Agreements

A recent ruling by the U.S. Court of Appeals for the Seventh Circuit affirming a decision compelling arbitration provides a “how to” guideline for using online terms and conditions to form a binding agreement....more

New Hampshire Enacts Law Overhauling Its Motor Vehicle Retail Installment Sales Act

Any business involved in motor vehicle installment financing in New Hampshire needs to assess the multiple and significant changes to a key law that have been enacted with immediate effect....more

FTC CFPB Enforcement Report — Moving the Metal: The Auto Finance Podcast [Audio]

In this episode of the Moving the Metal podcast, hosts Brooke Conkle and Chris Capurso delve into the Federal Trade Commission's (FTC) recent report to the Consumer Financial Protection Bureau (CFPB). This report responds to...more

FTC and Arizona AG Reach $2.6 Million Settlement with Motor Vehicle Dealer Over Alleged Deceptive and Discriminatory Sales and...

Last week, the Federal Trade Commission (FTC) and the State of Arizona announced a joint action against Coulter Motor Company, an Arizona-based motor vehicle dealership, and its former general manager, for allegedly engaging...more

Loans, Retail Installment Contracts, and Refinancing Programs — Moving the Metal: The Auto Finance Podcast [Audio]

In this episode, Brooke Conkle and Chris Capurso delve into the topic of refinancing and its impacts on the auto finance industry. They are joined by special guest Jason Cover, who provides insights and education on retail...more

Regulators Promote “All-of-Government” Solar Energy Market Initiative

On August 7, the U.S. Department of Treasury hosted a virtual briefing to discuss the steps that the Biden-Harris administration is taking to address perceived unfair and deceptive practices in the consumer solar energy...more

The CFPB’s Report on Negative Equity in Auto Lending - Moving the Metal: The Auto Finance Podcast [Audio]

In this episode of Moving the Metal, Troutman Pepper attorneys Brooke Conkle and Chris Capurso discuss the Consumer Financial Protection Bureau’s (CFPB) new report on negative equity in auto lending. This report, the first of...more

The CARS Rule — Moving the Metal: The Auto Finance Podcast [Audio]

In this inaugural episode of Moving the Metal, Troutman Pepper attorneys Brooke Conkle and Chris Capurso examine the major requirements of the FTC's proposed CARS Rule. After a refresher on the rule's requirements, Brooke and...more

CFPB Releases Supervisory Highlights Focusing on Debt Collection and Loan Servicing Practices

On July 2, the Consumer Financial Protection Bureau (CFPB or Bureau) published the summer edition of its Supervisory Highlights, focusing on examinations of auto and student loan servicing companies and debt collectors that...more

CFPB Report Foreshadows Increased Scrutiny of Negative Equity in Auto Lending

Yesterday, the Consumer Financial Protection Bureau (CFPB or Bureau) released a report on the state of negative equity in auto lending. The CFPB says it found that financing negative equity creates increased risks for...more

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