On July 27, 2023, the Board of Governors of the Federal Reserve System (FRB), the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, FBAs) issued their long-awaited...more
In the last eight months, the Consumer Financial Protection Bureau (CFPB) has signaled its intent to expand its use of abusiveness theories in enforcement matters. In March, the CFPB rescinded the previous administration's...more