The CARS Rule — Moving the Metal: The Auto Finance Podcast
Auto Finance – The Holder Rule — The Consumer Finance Podcast
Introduction to The Consumer Finance Podcast
Dancing to Their Own Tune: Empowering Consumers Through Self-Service
In this inaugural episode of Moving the Metal, Troutman Pepper attorneys Brooke Conkle and Chris Capurso examine the major requirements of the FTC's proposed CARS Rule. After a refresher on the rule's requirements, Brooke and...more
In a move that underscores the importance of clarity and accuracy in consumer-facing terms and conditions, the Consumer Financial Protection Bureau recently issued Circular 2024-03, addressing the use of unlawful or...more
Companies that provide consumer financial services and products be warned—a careful review of your fine print may be in order. Although broad disclaimers, liability waivers, and releases tend to be commonplace in general...more
On June 4, the CFPB issued a circular targeting the deceptive use of fine print in consumer financial contracts to include unlawful or unenforceable terms. In a press release issued the same day, the CFPB stressed that these...more
The Consumer Financial Protection Bureau (CFPB or Bureau) has issued a circular warning covered persons that including unlawful or unenforceable terms and conditions in consumer contracts can violate the prohibition on...more
On June 4, 2024, the Consumer Financial Protection Bureau (“CFPB”) issued a Consumer Financial Protection Circular 2024-03 (“Circular”) warning that the use of unlawful or unenforceable terms and conditions in contracts for...more
Troutman Pepper attorneys Brooke Conkle and Chris Capurso discuss the Federal Trade Commission's "Holder Rule" in the third of five special episodes devoted to auto finance issues. Although the Holder Rule has been around...more
In connection with the petition to ban pre-dispute consumer arbitration agreements pending before the Consumer Financial Protection Bureau (CFPB) and a recent Senate Judiciary Committee hearing on “forced arbitration,”...more
A lengthy decision recently issued by the U.S. District Court for the Eastern District of Pennsylvania, Pennsylvania by Shapiro v. Mariner Fin., LLC, No. CV 22-3253, 2024 WL 169654 (E.D. Pa. Jan. 12, 2024) (Hodge, J.), may...more
On September 9, 2014, then-Governor Jerry Brown of California signed into law Assembly Bill No. 2365. The law, which went into effect in January of 2015, prohibits contracts for the sale or lease of consumer goods from...more
In this article, we share a list of the top 10 biggest fines and penalties from our monthly bites for 2023....more
On January 9, 2024, the California Department of Financial Protection and Innovation (DFPI) announced that it entered into a consent order with a Delaware fintech company that provided California consumers with access...more
Washington now joins the list of states that have enacted or proposed legislation adopting so-called anti-evasion provisions, including legislation passed in Minnesota, Connecticut, Nebraska, and proposed in Florida. On...more
The Consumer Financial Protection Bureau (CFPB or Bureau) released its 14th annual report to Congress in fulfillment of its requirements under the Credit Card Accountability Responsibility and Disclosure (CARD) Act. For the...more
The Consumer Financial Protection Bureau (“CFPB”) announced on Monday that it and 41 states and the District of Columbia had resolved a multistate investigation in the leasing activities engaged in by specialty consumer...more
Usury is the unlawful lending of money at unreasonably high rates of interest. So, what is unreasonable? And what happens if your loan goes beyond that amount?...more
The Consumer Duty applies to firms that materially influence consumer outcomes. The Consumer Duty (Duty) (as set out in the FCA’s Policy Statement PS22/9 and guidance document FG22/5) will come into force at the end of...more
We thank you for joining us over the past three years and are pleased to resume our CFPB Bites of the Month series in 2023! Consumer financial services concerns continue to be front and center in the daily news cycles....more
In our previous client alert, The UK Consumer Duty: Next Steps for Private Fund Managers, we explored the new consumer duty rules contained in PS22/9: A new Consumer Duty. As we noted, the duty applies to managers who provide...more
The Council of the EU and the European Parliament have reached provisional political agreement on the proposed Directive on consumer credits to revise and replace the Consumer Credit Directive (2008/48/EC) (CCD II). The...more
Hogan Lovells Financial Services Regulatory team shares insights on HM Treasury's recently published response to its October 2021 consultation on the scope and form of a new regulatory regime for Buy-Now Pay-Later (BNPL)...more
On May 26, 2022, the Eleventh Circuit issued an opinion reversing the Southern District of Florida’s denial of the appellant’s motion to compel arbitration, therein finding that the district court erred in failing to apply...more
The Consumer Finance Podcast provides reliable, insightful, and entertaining industry-specific content central to consumer finance services. Hosted by veteran Troutman Pepper CFS Partner Chris Willis, this podcast features...more
Commercial finance providers doing business in New York will have more time to comply with New York’s new law requiring consumer-like disclosures to be made for certain types of commercial financing. ...more
On September 1, 2021, the Commonwealth of Massachusetts, through the Massachusetts attorney general, entered into a settlement agreement and related Assurance of Discontinuance with a sales finance company. The AOD identifies...more