Today, the Consumer Financial Protection Bureau (CFPB or Bureau) published a policy statement in the Federal Register outlining its approach to addressing criminally liable regulatory offenses. This publication comes in...more
6/27/2025
/ Consumer Financial Protection Bureau (CFPB) ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Deregulation ,
Enforcement Actions ,
Enforcement Priorities ,
Executive Orders ,
Financial Crimes ,
Financial Regulatory Reform ,
Penalties ,
Regulatory Agenda ,
Regulatory Reform ,
Reporting Requirements ,
Trump Administration ,
White Collar Crimes
Last week, the Consumer Financial Protection Bureau (CFPB or Bureau) submitted several regulatory proposals to the Office of Management and Budget (OMB) for review. Among the rules under consideration are those related to...more
6/10/2025
/ Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Dodd-Frank ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Mortgage Lenders ,
Mortgage Loan Originators ,
Mortgage Servicers ,
Mortgages ,
OMB ,
Proposed Rules ,
Regulation X ,
Regulation Z ,
Regulatory Agenda ,
Regulatory Oversight ,
Regulatory Reform
We are pleased to share with you our latest publication, “Navigating Change: First 100 Days under the Trump Administration,” authored by our Digital Assets + Blockchain team. This retrospective examines the pivotal...more
5/29/2025
/ Blockchain ,
Cryptocurrency ,
Digital Assets ,
Executive Orders ,
FDIC ,
Federal Reserve ,
Financial Regulatory Reform ,
FinTech ,
Government Agencies ,
Investment Opportunities ,
Proposed Legislation ,
Regulatory Agenda ,
Regulatory Oversight ,
Regulatory Requirements ,
Securities Regulation ,
Trump Administration
On May 15, the Consumer Financial Protection Bureau (CFPB or Bureau) officially rescinded its May 2022 interpretive rule concerning the scope of state enforcement authority under § 1042 of the Consumer Financial Protection...more
5/22/2025
/ Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Enforcement Actions ,
Financial Regulatory Reform ,
Regulatory Authority ,
Regulatory Oversight ,
Regulatory Reform ,
State and Local Government ,
State Attorneys General ,
Statutory Interpretation ,
UDAAP
On May 14, the Consumer Financial Protection Bureau (CFPB or Bureau) published a proposed rule to rescind amendments to its Procedures for Supervisory Designation Proceedings, originally adopted in 2022 and 2024. This...more
5/19/2025
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Financial Institutions ,
Financial Regulatory Reform ,
Non-Bank Lenders ,
Proposed Amendments ,
Proposed Rules ,
Public Comment ,
Regulatory Agenda ,
Regulatory Oversight ,
Rescission ,
Risk Management ,
Supervision
Yesterday, the Consumer Financial Protection Bureau (CFPB or Bureau) released a proposed rule to rescind its previous regulation requiring nonbank entities to report certain agency and court orders to a Bureau registry....more
5/14/2025
/ Comment Period ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Final Rules ,
Financial Regulatory Reform ,
Financial Services Industry ,
Non-Bank Lenders ,
Proposed Rules ,
Regulatory Requirements ,
Reporting Requirements ,
Rescission ,
Rulemaking Process
This week, the Consumer Financial Protection Bureau (CFPB or Bureau) released a memo to staff outlining its new supervision and enforcement priorities for 2025....more
4/18/2025
/ Banking Sector ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Discriminatory Lending Practices ,
Enforcement Actions ,
Fair Credit Reporting Act (FCRA) ,
Fair Lending ,
FDCPA ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Mortgages ,
Regulatory Reform ,
Regulatory Requirements ,
Supervisory Guidance ,
Trump Administration
The Consumer Financial Protection Bureau (CFPB or Bureau) agreed to vacate its controversial credit card late fee rule in a joint motion for entry of consent judgment filed in Chamber of Commerce of the United States of...more
4/16/2025
/ Administrative Procedure Act ,
CARD Act ,
Consent ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Cards ,
Final Rules ,
Financial Regulatory Reform ,
Financial Services Industry ,
Judicial Authority ,
Late Fees ,
Penalties ,
Regulatory Requirements ,
Statutory Violations ,
Vacated
In this episode of The Consumer Finance Podcast, Chris Willis is joined by colleagues Jesse Silverman and James Kim to discuss recent developments in New York's legislative efforts to strengthen its consumer financial...more
On March 20, the Arkansas governor signed into law Arkansas Act 347, known as the Earned Wage Access Services Act. Sponsored by Representative David Ray (R) and Senator Ben Gilmore (R), this legislation aims to regulate...more
3/25/2025
/ Arkansas ,
Debt Collection ,
Disclosure Requirements ,
Earned Wage Access ,
Fees ,
Financial Regulatory Reform ,
Financial Services Industry ,
New Legislation ,
Regulatory Reform ,
Regulatory Requirements ,
Wages
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
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 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 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
On January 10, the Alaska Legislature introduced Senate Bill 39 that aims to amend the state’s Small Loan Act. This proposed legislation seeks to implement significant changes, including the introduction of a predominant...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
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
As part of a flurry of last minute regulatory activity by the Biden administration’s Consumer Financial Protection Bureau (CFPB or Bureau), on January 15, the CFPB published an advisory opinion in the Federal Register...more
1/23/2025
/ Advisory Opinions ,
Biden Administration ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Earned Wage Access ,
Final Rules ,
Financial Regulatory Reform ,
Financial Services Industry ,
Payroll Deductions ,
Regulation Z ,
Regulatory Agenda ,
Truth in Lending Act (TILA)
This week, New York became the latest state to introduce legislation aimed at regulating Earned Wage Access (EWA) services. Assembly Bill 258 titled — “An Act to Amend the Banking Law, in Relation to Providing for Income...more
1/10/2025
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Disclosure Requirements ,
Earned Wage Access ,
Financial Regulatory Reform ,
Financial Services Industry ,
New York ,
NYDFS ,
Proposed Legislation ,
Regulation Z ,
Regulatory Agenda ,
Truth in Lending Act (TILA) ,
Wages
Late last year, we discussed the Consumer Financial Protection Bureau’s (CFPB or Bureau) proposed rule aimed at supervising larger technology companies offering digital wallets and payment apps. On November 21, the CFPB...more
Last month, we discussed the California Department of Financial Protection and Innovation’s (DFPI) newly approved regulations for direct-to-consumer earned wage access (EWA) products. These regulations, approved by the Office...more
11/26/2024
/ California Consumer Financial Protection Law (CCFPL) ,
Consumer Financial Products ,
Department of Financial Protection and Innovation (DFPI) ,
Earned Wage Access ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Loans ,
New Regulations ,
Regulatory Requirements ,
Wage and Hour
This week, the Consumer Financial Protection Bureau (CFPB or Bureau) issued its final rule on personal financial data rights, purportedly aimed at enhancing consumer control over their financial data and promoting competition...more
10/24/2024
/ Banks ,
Consumer Data Requests ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Data Management ,
Dodd-Frank ,
Final Rules ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Open Banking
On October 11, the Office of Administrative Law (OAL) approved the California Department of Financial Protection and Innovation’s (DFPI) proposed regulations on direct-to-consumer (i.e., non-employer offered) earned wage...more
10/24/2024
/ Banks ,
California ,
Consumer Financial Products ,
Department of Financial Protection and Innovation (DFPI) ,
Earned Wage Access ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Loans ,
New Regulations ,
Office of Administrative Law Judges (OALJ) ,
Wage and Hour