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
The CFPB entered into a Consent Order with U.S. Bank National Association over allegations that U.S. Bank pressured and incentivized its employees to open unauthorized accounts, in violation of the Consumer Financial...more
In a March 25 letter to Rohit Chopra, Director of the Consumer Financial Protection Bureau, AGs from 21 states, plus the Hawaii Office of Consumer Protection, responded to the CFPB’s Notice and Request for Comment Regarding...more
Does Ownership and Management Structure Matter? Fiduciary Relationships - Special confidence placed in one who in equity and good conscience is bound to act in good faith and in due regard to the one reposing confidence....more
Crazy times, right? Chances are you've heard this refrain numerous times over the last seven months, most notably on Zoom calls during the crushing silence of someone on the call forgetting to unmute his or her microphone....more
Alert May 18, 2020 The economic impact of COVID-19 has already proven catastrophic for many businesses and consumers. Many employers are reducing their staffing or closing their doors permanently. As of May 8, 2020, the...more
Regulatory uncertainty remains one of the most significant challenges to finance companies that want to develop creative and innovative products and services. Federal and state agencies have implemented policies to facilitate...more
The OCC, Federal Reserve Board, FDIC, NCUA and CFPB have issued an “Interagency Statement on the Use of Alternative Data in Credit Underwriting.”...more
On December 3rd, the Board of Governors of the Federal Reserve System, the Consumer Financial Protection Bureau, the Federal Deposit Insurance Corporation, the National Credit Union Administration and the Office of the...more
On June 6, 2018, the House Financial Services Committee’s Subcommittee on Financial Institutions and Consumer Credit will hold a hearing entitled “Improving Transparency and Accountability at the Bureau of Consumer Financial...more
On July 10, 2017, in a surprise move, the Consumer Financial Protection Bureau (CFPB or Bureau) issued its long awaited final rule on arbitration (Final Arbitration Rule). This rule-making has been a lightning rod issue for...more
The CFPB has published a notice in the Federal Register announcing that a meeting of its Consumer Advisory Board will be held on March 2, 2017. The notice indicates that the Board will discuss the consumer credit information...more
On Thursday, February 25, 2016, the CFPB held a Consumer Advisory Board meeting in which it outlined its forward-looking supervision and enforcement priorities. After the Board meeting, the CFPB published a summary of these...more
The Consumer Financial Protection Bureau (CFPB) has stepped up its enforcement actions alleging deceptive and unfair practices in marketing and billing for add-on credit protection products. Add-on products have been one of...more
Why it matters - In a not-unexpected announcement, the Consumer Financial Protection Bureau (CFPB) revealed a $25 million settlement with PayPal resolving allegations that the company illegally signed consumers up for...more
On Tuesday, March 17, the Consumer Financial Protection Bureau (CFPB) announced a “Request for Information Regarding Credit Card Market.” It follows the 2009 CARD Act’s requirement that the CFPB conduct a review of the...more