Requiem for the Rules: The Rise and Fall of the Junk Fee and CARS Rules — Moving the Metal: The Auto Finance Podcast
Introducing the Consumer Financial Services Year in Review Series: A Look at What’s to Come — The Consumer Finance Podcast
Dissecting Oral Arguments in NADA's Challenge to the CARS Rule — Moving the Metal: The Auto Finance Podcast
Consumer Finance Monitor Podcast Episode: The Regulation of Negative Option Consumer Contracts – Silence as Consent
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
The first two months of 2025 were filled with numerous consumer protection actions by state AGs against vehicle dealers and players in the mortgage space, among others. ...more
New York lawmakers—with full support from the attorney general—are pushing a sweeping expansion of consumer protection laws that could turn routine financial transactions into the next big class action battleground and expand...more
Financial services companies may feel relief from the aggressive federal oversight and regulation that defined the past decade. However, regulatory risk has not disappeared—it has shifted. ...more
The Consumer Financial Protection Bureau (CFPB) issued a proposed rule under Regulation AA to address the use of restrictive and coercive clauses in consumer financial contracts. This proposal seeks to prohibit terms in...more
The CFPB has published a proposed rule that would ban companies from using contract clauses that the bureau said limit fundamental freedom, including those that waive a consumer’s legal rights and fine print that suppresses...more
The Consumer Financial Protection Bureau (CFPB or Bureau) proposed a new rule aimed at banning certain contractual provisions in agreements for consumer financial products or services. The CFPB’s proposal targets certain...more
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
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
On December 12, 2024, the Federal Trade Commission (“FTC”) announced its Combating Auto Retail Scams Rule, otherwise known as the “CARS Rule,” setting new requirements on the sale, financing, and leasing of vehicles by motor...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
In a move to protect homeowners from deceptive practices, the Florida Senate has passed CS/CS/SB 770, a bill that regulates residential loan alternative agreements for the sale of residential real property. The bill, which...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
In 2013, the Consumer Financial Protection Bureau (CFPB) issued a bulletin on indirect auto lending that took the industry by storm. As we approach the five-year anniversary of the memo’s issuance, it’s valuable to reflect on...more
Auto lenders, like many private citizens, began 2017 curious as to what change the impending Trump administration would bring. In the landscape of government enforcement, however, the consensus amongst industry participants...more
On August 6, 2015, a California federal judge requested further briefing on whether the arbitration clause in a lender’s Visa gift card user agreement may be unenforceable against a putative class action plaintiff – raising...more