A CFPB Circular from June bears additional scrutiny from across the financial services spectrum. Despite most courts allowing “savings” clauses in contracts, the Consumer Financial Protection Bureau (CFPB) indicates that the...more
The Federal Deposit Insurance Corporation (“FDIC”) on August 18, 2022 issued updated Supervisory Guidance on banks assessing multiple re-presentment fees against customers’ accounts. This follows the March 2022 FDIC Consumer...more