In April 2024, the Consumer Financial Protection Bureau (CFPB or Bureau) and the Commissioner for Justice and Consumer Protection of the European Commission (European Commission) announced that three meetings had been...more
5/13/2024
/ Banking Sector ,
Buy Now Pay Later (BNPL) ,
Consumer Financial Protection Bureau (CFPB) ,
Digital Wallets ,
Enforcement ,
Enforcement Priorities ,
EU ,
European Commission ,
Financial Services Industry ,
Joint Statements ,
Open Banking ,
Payment Systems ,
Regulatory Agenda
On February 16, 2024, the Consumer Financial Protection Bureau (CFPB or Bureau) announced that it is updating its internal supervisory appeals process for institutions seeking to appeal a compliance rating or an adverse...more
Welcome to the Payday and Small-Dollar Lending chapter of our annual report Consumer Financial Services 2023 Year in Review.
Looking Ahead to 2024 -
Regulators may take additional regulatory and enforcement action...more
Welcome to the Fintech chapter of our annual report Consumer Financial Services 2023 Year in Review.
Looking Ahead to 2024 -
The CFPB is expected to finalize rulemaking authorizing supervision of payment application...more
2/16/2024
/ Apple Pay ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Department of Financial Protection and Innovation (DFPI) ,
Enforcement Actions ,
Financial Services Industry ,
FinTech ,
GAO ,
Google ,
New Legislation ,
Nonbank Firms ,
OCC ,
Payday Loans ,
Payment Systems ,
PayPal ,
Regulation Z ,
Third-Party Relationships ,
Truth in Lending Act (TILA) ,
Venmo ,
Wages
On January 8, 2024, the Office of Inspector General (OIG) issued an Evaluation Report (Report) concluding that the Consumer Financial Protection Bureau (CFPB or Bureau) should “enhance certain aspects of its enforcement...more
On August 17, 2023, the Consumer Financial Protection Bureau (CFPB) announced that it had taken action against a residential mortgage loan originator that provided illegal incentives to real estate brokers and agents in...more
8/28/2023
/ Civil Monetary Penalty ,
Consent Order ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Enforcement Actions ,
Kickbacks ,
Marketing Services Agreements ,
Mortgage Lenders ,
Mortgage Loan Originators ,
Mortgages ,
Real Estate Brokers ,
Regulation X ,
RESPA
On June 12, 2023, an Eleventh Circuit panel issued an opinion affirming a sanctions order against the Consumer Financial Protection Bureau (CFPB) premised on the CFPB’s “derail[ment]” of multiple depositions in contravention...more
On Tuesday, April 11, 2023, a three-judge panel of the United States Court of Appeals for the Third Circuit affirmed the dismissal of a putative class action alleging that JP Morgan Chase Bank, N.A. (Chase) failed to itemize...more
2022 saw a flurry of regulatory activity by federal enforcement agencies — most notably, the Consumer Financial Protection Bureau (CFPB, or Bureau) — as the industry began to experience the full effects of the change in...more
2/22/2023
/ Automotive Loans ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Credit Cards ,
Credit Reports ,
Debt Collection ,
Financial Services Industry ,
FinTech ,
Mortgages ,
Payday Loans ,
Prepaid Payment Products ,
Privacy Laws ,
Student Loans
In September 2022, the Consumer Financial Protection Bureau (CFPB) released a special edition of Supervisory Highlights regarding recent examination findings related to student loan servicing. The Supervisory Highlights focus...more
In August 2022, the Consumer Financial Protection Bureau (CFPB) published a circular confirming that, under certain circumstances, entities may “violate the prohibition on unfair acts or practices in the Consumer Financial...more
10/4/2022
/ Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Information ,
Data Breach ,
Data Management ,
Data Protection ,
Data Security ,
Financial Services Industry ,
New Circular ,
Personal Data ,
Sensitive Personal Information ,
Unfair or Deceptive Trade Practices
On July 28, 2022, the Consumer Financial Protection Bureau (CFPB) issued a Consent Order against a large bank (the Bank), claiming that the Bank created sales pressure on its employees that encouraged employees to...more
8/19/2022
/ Bank Accounts ,
Banking Sector ,
Banks ,
Civil Monetary Penalty ,
Consent Order ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Cards ,
Credit Reports ,
Enforcement Actions ,
Families First Coronavirus Response Act (FFCRA) ,
Financial Services Industry ,
Line of Credit ,
Restitution ,
Sensitive Personal Information ,
Truth in Lending Act (TILA)
On March 1, 2022, the Consumer Financial Protection Bureau (CFPB) issued a report titled Medical Debt Burden in the United States (Report) highlighting the complicated and burdensome nature of the medical billing system in...more
[co-authors: Amelie Hopkins, and Collin Grier]
The year 2021 started with the hope of COVID-19 vaccines and a return to (relative) normalcy, only to conclude with new variants that presented new challenges and extended...more
2/23/2022
/ AMG Capital Management LLC v FTC ,
Automotive Loans ,
Banking Sector ,
Borrowers ,
Collins v Yellin ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Protection Act ,
Credit Reporting Agencies ,
Credit Reports ,
Creditors ,
Debit and Credit Card Transactions ,
Debt Collection ,
Debtors ,
Dodd-Frank ,
Enforcement Actions ,
Financial Services Industry ,
FinTech ,
Lenders ,
Loan Servicing ,
Mortgage Loan Originators ,
Mortgage Servicers ,
Payday Loans ,
Prepaid Payment Products ,
SCOTUS ,
Settlement ,
Small Dollar Lenders ,
Student Loans ,
TCPA ,
TransUnion LLC v Ramirez
On January 26, 2022, the Consumer Financial Protection Bureau (CFPB) issued a Request for Information Regarding Fees Imposed by Providers of Consumer Financial Products or Services (RFI). In the RFI, the CFPB seeks public...more
On January 6, 2021, the Second Circuit issued an order criticizing and declining to adopt a Third Circuit ruling regarding the scope of the term “unsolicited advertisement” under the Telephone Consumer Protection Act...more
In August 2021, the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), and the Board of Governors of the Federal Reserve System (the Federal Reserve and, collectively with the...more
On July 12, 2021, the Consumer Financial Protection Bureau (CFPB) issued a consent order (the Consent Order) against a Fintech company that facilitates home improvement loans (the Fintech). The CFPB claims that the Fintech...more
7/27/2021
/ Consent Order ,
Consumer Contracts ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Consumer Loan Companies ,
Enforcement Actions ,
FinTech ,
Fraud ,
Merchants ,
Point of Sale Terminals
On June 3, 2021, the Second Circuit ruled that the New York State Department of Financial Services (DFS) lacked legal standing to challenge the Office of the Comptroller of the Currency’s (OCC’s) fintech charter program. The...more
6/18/2021
/ Appeals ,
Article III ,
Depository Institutions ,
Dismissals ,
FinTech ,
Fintech Charter ,
NYDFS ,
OCC ,
Remand ,
Reversal ,
Standing
On May 3, 2021, the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC) sent notification letters reminding the nation’s largest apartment landlords of federal protections in place to keep tenants...more
5/12/2021
/ Centers for Disease Control and Prevention (CDC) ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Eviction ,
FDCPA ,
Federal Trade Commission (FTC) ,
Infectious Diseases ,
Landlords ,
Moratorium ,
Relief Measures ,
Rental Property ,
Tenants
On March 19, 2021, the Consumer Financial Protection Bureau (CFPB) released its annual report to Congress regarding its administration of the Fair Debt Collection Practices Act (FDCPA). The CFPB and the Federal Trade...more
On February 3, 2021, California’s Department of Financial Protection and Innovation (DFPI) announced that it has commenced its first formal enforcement action and launched a separate investigation into student loan debt...more