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Democratic Senators send letter to federal banking agencies raising concerns about fraudulent transactions

A group of five Democratic Senators have sent a letter to the Federal Reserve, OCC, FDIC, and NCUA asking them to take several steps to protect consumers from scams when using Zelle to transfer money....more

CFPB issues new report on buy-now-pay-later

The CFPB has issued a new report ,“Consumer Use of Buy Now, Pay Later: Insights from the CFPB Making Ends Meet Survey,” that looks at the financial profiles of consumers who use buy-now-pay-later (BNPL) products....more

CFPB issues report on delivery of public benefits payments

A new CFPB report, “Issue Spotlight: Public Benefits Delivery & Consumer Protection,” looks at what it describes as “the challenges that recipients of public benefits programs offering cash assistance encounter in accessing...more

SCOTUS agrees to decide whether CFPB’s funding is unconstitutional but will not hear case until next Term

The U.S. Supreme Court has granted the certiorari petition filed by the CFPB seeking review of the Fifth Circuit panel decision in Community Financial Services Association of America Ltd. v. CFPB. In that decision, the Fifth...more

CFPB issues findings on “suppression” of actual payment data by major credit card issuers

In May 2022, the CFPB sent letters to the chief executive officers of six major credit card issuers regarding their companies’ payment furnishing practices. On February 16, the CFPB published a blog post about its key...more

New CFPB report and blog post look at third-party debt collections tradeline reporting and medical debt furnishing

The CFPB issued a new report, “Market Snapshot: An Update on Third-Party Debt Collections Tradelines Reporting,” that looks at trends in credit reporting of debt in collections from 2018 to 2022. It also published a new blog...more

FTC issues annual ECOA report to CFPB (UPDATED)

The FTC recently sent its annual letter to the CFPB reporting on the FTC’s activities related to the Equal Credit Opportunity Act (ECOA) and Regulation B.  The new letter reports on the FTC’s activities in 2022.  The Bureau...more

CFPB report of decline in bank revenues from overdraft and NSF fees follows President Biden’s targeting of “junk fees” State of...

In a new report published last week titled “Banks’ overdraft/NSF fee revenue declines significantly compared to pre-pandemic levels,” the CFPB reported that its most recent analysis found that bank overdraft/NSF fee revenue...more

ABA files amicus brief in support of bank’s position that TILA credit card offset prohibition does not apply to amounts owed on a...

The issue of whether a home equity line of credit (HELOC) that can be accessed using a credit card is a “credit card plan” subject to the Truth in Lending Act’s setoff prohibition is currently before the U.S. Court of Appeals...more

Briefing on CFPB certiorari petition seeking review of Fifth Circuit ruling that CFPB’s funding is unconstitutional and CFSA...

The briefing on the CFPB’s certiorari petition seeking review of the Fifth Circuit panel decision in Community Financial Services Association of America Ltd. v. CFPB was distributed to the Supreme Court yesterday for...more

CFPB proposes significant changes to credit card late fee rules, including reduction in late fee safe harbor amounts and...

We suspected something was afoot when December 2022 came and went without the CFPB announcing its annual inflation adjustments to the credit card late fee safe harbor amounts set forth in Regulation Z (which implements the...more

Banking trade groups highlight CFPB SBREFA obligations for credit card penalty fees rulemaking

In a letter to Director Chopra, five banking trade groups address the CFPB’s obligation to comply with the Small Business Regulatory Enforcement Fairness Act of 1996 (SBREFA) before proposing a rule on credit card late fees...more

CFPB files opposition to CFSA cross-petition for certiorari; payment processor trade group files amicus brief in support of...

The CFPB has filed its brief in opposition to the cross-petition for certiorari filed by Community Financial Services Association (CFSA). The CFPB’s certiorari petition seeks review of the Fifth Circuit panel decision in...more

Federal Reserve Board final rule on benchmark replacements for contracts that use LIBOR published in Federal Register; Fannie Mae...

The final rule issued by the Federal Reserve Board to implement the LIBOR Act by establishing default rules for benchmark replacements in certain contracts that use LIBOR as a reference rate was published in today’s Federal...more

CFPB issues request for information on consumer credit card market # 2

The CFPB has issued a new request for information (RFI) to inform its biennial review of the credit card market mandated by the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act).  Comments on the...more

CFPB issues circular on negative option marketing

The CFPB has issued a new circular (2023-01) that addresses the circumstances under which “negative option marketing practices” can violate the CFPA prohibition of unfair, deceptive, or abusive acts or practices....more

Second Circuit holds inclusion on credit report of student loan debt alleged to have been discharged in bankruptcy did not make...

The U.S. Court of Appeals for the Second Circuit recently ruled that a plaintiff who alleged that Experian had violated the Fair Credit Reporting Act by including a discharged student loan debt on his credit report had not...more

CFSA files opposition to CFPB’s certiorari petition seeking review of Fifth Circuit ruling that CFPB’s funding is unconstitutional...

Community Financial Services Association (CFSA) has filed its brief in opposition to the CFPB’s certiorari petition seeking review of the Fifth Circuit panel decision in Community Financial Services Association of America...more

California DFPI releases modified proposed Student Loan Servicing Act regulations

On September 9, 2022, the California Department of Financial Protection and Innovation (DFPI) proposed to amend its student loan servicing regulations, which we previously covered  here.  After reviewing public comments, on...more

CFPB proposes registry for supervised nonbanks using form contracts containing arbitration provisions, waivers, or other limits

The CFPB has issued a proposed rule to establish a system for the registration of nonbanks subject to CFPB supervision that use “certain terms or conditions that seek to waive consumer rights or other legal protections or...more

CFPB files amicus brief in Fourth Circuit arguing Regulation E protections apply to prepaid account loaded with pandemic-related...

The CFPB has filed an amicus brief in Mohamed v. Bank of America, N.A. in which it argues that a prepaid card loaded with pandemic-related unemployment benefits is a “prepaid account” subject to Regulation E, including its...more

California expands co-signer notice requirement

On August 15, 2022, the California governor signed SB 633 into law, expanding the obligations of creditors obtaining the signatures of more than one person on a consumer credit contract, including a motor vehicle lease, who...more

New Jersey federal court rules misleading collection letter alone does not establish Article III standing

In an unpublished opinion, a New Jersey federal district court has ruled that a plaintiff did not have Article III standing to assert a claim under the Fair Debt Collection Practices Act based solely on her receipt of an...more

CFPB adds six new items to Fall 2022 rulemaking agenda, including overdraft fees, fees for insufficient funds, and credit card...

The CFPB has published its Fall 2022 rulemaking agenda as part of the Fall 2022 Unified Agenda of Federal Regulatory and Deregulatory Actions.  The agenda’s preamble indicates that “[t]he Bureau reasonably anticipates having...more

CFPB annual report on consumer complaints about “Big 3” consumer reporting agencies flags concerns with use of automated processes

The CFPB has issued its “Annual report of credit and consumer reporting complaints” that reports on consumer complaints submitted to the CFPB regarding the three largest nationwide consumer reporting agencies (NCRAs)—Equifax,...more

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