Recent Consumer Financial Protection Bureau ("CFPB") guidance reiterates that creditors must provide consumers with accurate and individualized explanations for adverse actions—a task made more difficult by the complexity of...more
10/12/2023
/ Adverse Action ,
Algorithms ,
Artificial Intelligence ,
Consumer Credit Protection ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
ECOA ,
Financial Institutions ,
Financial Services Industry ,
Machine Learning ,
Regulation B
The Massachusetts Student Loan Borrower Bill of Rights The SL Bill of Rights came into effect on July 1, 2021, and the DOB issued its implementing regulations on the same day. Building upon and codifying earlier proposed...more
The Situation: For the past 10 years, regulated entities and others have sought more definition concerning the nature and scope of claims the Consumer Financial Protection Bureau ("CFPB") might bring alleging "abusive"...more
The Situation: The Office of the Comptroller of the Currency ("OCC") has appealed a decision from the Southern District of New York that concluded that the OCC lacks the authority to grant "Fintech Charters" to nondepository...more
1/6/2020
/ Consumer Financial Products ,
Depository Institutions ,
FDIC ,
Financial Services Industry ,
FinTech ,
Fintech Charter ,
Madden v Midland Funding ,
National Bank Act ,
National Bank Charters ,
Non-Depository Institutions ,
NYDFS ,
OCC ,
Popular ,
Preemption ,
Usury ,
Valid When Made Doctrine