On September 17, the Consumer Financial Protection Bureau (CFPB or Bureau) published Circular 2024-05 (Circular) addressing whether a financial institution violates the Electronic Fund Transfer Act (EFTA) and Regulation E by...more
On Sept. 17, the Consumer Financial Protection Bureau (CFPB) published guidance for federal and state consumer protection enforcement officials to use to prevent banks and credit unions from charging overdraft fees in certain...more
On January 24, 2024, a week after issuing its proposed rulemaking for overdraft services, the Consumer Financial Protection Bureau (“CFPB”) issued its proposed rulemaking on non-sufficient funds (NSF) fees....more
Last week, the defendant filed its answer brief in Bratton v. Sisters of Charity of Leavenworth Health System, Inc., an appeal now pending before the Montana Supreme Court involving a challenge to the defendant’s use of...more
The CFPB’s Final Rule on prepaid cards includes, in addition to the long form disclosure requirements discussed in our November 21st blog post, highly detailed requirements for providing “preacquisition” disclosures to...more
The American Bankers Association has submitted a letter commenting on the CFPB’s request for approval from the Office of Management and Budget to conduct “a national web survey of 8,000 individuals as part of its study of...more
On October 27, 2015, the United States Department of Education issued 433 pages of new regulations governing student loan programs under the Student Assistance General Provisions regulations promulgated under the Higher...more
Since opening its doors for business, behavioral economics has played a central role in the CFPB’s regulatory agenda. Behavioral economists posit that consumers are not rational decision makers and instead have certain...more