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Credit Scores

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - December 2024

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - November 2024 # 4

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Orrick, Herrington & Sutcliffe LLP

FTC proposes fines, bans based on alleged credit repair scheme

On August 5, the FTC announced proposed court orders that would require a defendant credit repair operation, its owners and associated companies (collectively, defendants) to pay more than $12 million to resolve allegations...more

Ballard Spahr LLP

FTC Shuts Down Credit Repair Company

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The FTC has shut down Michigan-based Financial Education Services, a credit repair company that the agency says actually was a large pyramid scheme...more

Goodwin

Traps for the Unwary: Using Alternative Credit Data to Expand Credit Access to LMI Individuals and Underrepresented Communities

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Traditional credit underwriting methods, which are generally based on credit reports, have not always successfully captured the full picture of a borrower’s ability to repay. It is estimated that more than 45 million US...more

Orrick, Herrington & Sutcliffe LLP

FHFA announces updates for implementation of GSE credit score requirements

On February 29, FHFA announced updates related to the implementation of new credit score requirements for single-family loans acquired by Freddie Mac and Fannie Mae (GSEs). As previously covered by InfoBytes, FHFA released a...more

Troutman Pepper

Kentucky Introduces Legislation Requiring CRAs to Obtain Express Consumer Consent Prior to Furnishing a Consumer Report or Credit...

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On February 16, Kentucky state representative Steve Bratcher (R) introduced House Bill (HB) 578. The bill seeks to create a new section of the Kentucky Consumer Protection Act that would restrict how consumer reporting...more

Ballard Spahr LLP

Democratic Senators urge continued CFPB scrutiny of buy-now-pay-later products

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Democratic Senator Sherrod Brown, who chairs the Senate Banking Committee, and Democratic committee members Raphael Warnock and John Fetterman, have sent a letter to Director Chopra urging the CFPB to “continue focusing on”...more

Ballard Spahr LLP

CBA concludes blog post series countering CFPB information about CARD Act report

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The Consumer Bankers Association has issued the third and fourth blog posts in its four-part “Facts Matter” blog series on how the CFPB’s public statements can mislead market observers by painting a picture of the credit...more

Alston & Bird

EU’s Highest Court Issues Major AI Decision With Wide-Reaching Impact

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On 7 December 2023, the Court of Justice of the European Union (CJEU) issued an important decision on how the GDPR governs AI-assisted decisions. The case arose in the financial services context, with the court holding that...more

Troutman Pepper

A Tale of Two Credit Scores: Illinois Federal Court Denies Class Certification Of "Misleading" Credit Score Case

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On October 12, the U.S. District Court for the Northern District of Illinois denied certification of a putative class action asserting that TransUnion violated the Fair Credit Reporting Act (FCRA) and the Missouri...more

Bradley Arant Boult Cummings LLP

CFPB Issues Additional Guidance on Use of AI in Credit Underwriting

On September 19, the Consumer Financial Protection Bureau (CFPB) issued Circular 2023-03, which provides guidance as to how lenders must explain denials of applications of credit when the underwriting is based on artificial...more

Ballard Spahr LLP

Seventh Circuit Holds FTC Act Does not Allow Disgorgement to U.S. Treasury

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In FTC v. Credit Bureau Center, LLC, the Seventh Circuit recently held that Section 19 of the Federal Trade Commission Act does not allow the FTC to deposit excess funds awarded as restitution under Section 19 in the U.S....more

Troutman Pepper

CFPB Releases Blog Post Favoring Use of Self-Reported Cash Flow Data in Credit Underwriting

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On July 27, the Consumer Financial Protection Bureau (CFPB) released a new blog post, positing that cashflow data, broadly defined as the various inflows, outflows, and accumulated amounts in a consumer’s checking and savings...more

Troutman Pepper

Missouri Becomes Latest State to Establish Regulatory Framework for Earned Wage Access Products

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On July 7, Missouri Governor Mike Parson signed SB 103 into law, which prohibits any person from offering earned wage access (EWA) services without registering with the Division of Finance and paying an annual $1,000 fee. The...more

Troutman Pepper

Michigan House Bill Proposes Excluding Tenant Credit Scores from Rental Decisions

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The drumbeat to increase regulation of tenant screening continues, this time in Michigan. On June 15, Michigan state Representative Brenda Carter (D-29) introduced House Bill 4818, which proposes to amend landlord-tenant...more

Alston & Bird

Class Action & MDL Roundup 2023 Q1 – We Don’t Discount Confidentiality

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Welcome back to the Class Action & MDL Roundup! This edition covers notable class actions from the first quarter of 2023. In this edition, in pork we antitrust, paid time off is not pay, and if it’s free, it won’t cost...more

Brownstein Hyatt Farber Schreck

FHFA Commits to Flexible Timeline for Transitioning Credit Score Model Validation

Stemming from the Federal Housing Finance Agency’s (FHFA) 2019 validation and approval of credit score models final rule, the FHFA announced in October 2022 that Fannie Mae and Freddie Mac, the government-sponsored...more

Harris Beach PLLC

New Mortgage Fees Tied to Credit Scores Gain Media Attention, Raise Questions

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On May 1, 2023, new loan-level price adjustments (“LLPAs”) for single-family mortgages purchased by Fannie Mae and Freddie Mac (the “agencies”) went into effect. The Federal Housing Finance Agency (“FHFA”) – the independent...more

Orrick, Herrington & Sutcliffe LLP

FHFA seeks feedback on implementation of updated credit score requirements

On March 23, FHFA announced a two-phase plan for soliciting stakeholder input on the agency’s proposed process for implementing updated credit score requirements....more

Brownstein Hyatt Farber Schreck

FHFA Releases Fannie Mae and Freddie Mac Framework

On Thursday, Feb. 23, the Federal Housing Finance Agency (FHFA) announced a proposed rule to amend the Enterprise Regulatory Capital Framework (ERCF) for Fannie Mae and Freddie Mac (the Enterprises). FHFA indicated that the...more

Hudson Cook, LLP

CFPB Bites of the Month - February 2023 - "Every Compliance Rose Has Its Thorns"

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In this month's article, we share some of our top "bites" for the prior month covered during the February webinar....more

Wiley Rein LLP

Antitrust and Consumer Protection Laws Exclusions Bar Coverage for Underlying Litigation

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The United States District Court for the District of Minnesota, applying Minnesota law, has held that a media tech policy’s antitrust and consumer protection laws exclusions precluded coverage for the underlying litigation....more

Orrick, Herrington & Sutcliffe LLP

CFPB releases data on pandemic credit scores

On January 25, the CFPB released a blog post on credit score transitions during the Covid-19 pandemic. Using data available to the Bureau, the agency examined the transitions of consumers across credit score tiers using a...more

Hinch Newman LLP

FTC Finalizes Credit Karma Order Requiring Hefty Payment and the Cessation of Allegedly Deceptive ‘Pre-Approved’ Claims

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In September 2022, the Federal Trade Commission announced that it had taken action against credit services company Credit Karma for allegedly deploying dark patterns to misrepresent that consumers were “pre-approved” for...more

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