News & Analysis as of

Debt Collection UDAAP

Sheppard Mullin Richter & Hampton LLP

CFPB Withdraws Dozens of Guidance Documents as Part of Deregulatory Push

On May 12, the CFPB formally withdrew nearly 70 guidance materials—including policy statements, advisory opinions, circulars, and interpretive rules—through a Federal Register notice issued by Acting Director Russell...more

Venable LLP

CFPB Withdraws Guidance Documents: A Shift Toward Regulatory Restraint

Venable LLP on

The Consumer Financial Protection Bureau (CFPB) is taking a red pen to its own playbook.  In a sweeping move that signals a recalibration of its regulatory posture, the CFPB has announced the withdrawal of 67 guidance...more

Sheppard Mullin Richter & Hampton LLP

FTC Imposed $9.6 Million Judgement Against Debt Collector for Alleged Threats and Phantom Debt

On April 30, 2025, the FTC filed an amended complaint and final order in the U.S. District Court for the Northern District of Georgia against a debt collection company in connection with allegations that the company engaged...more

Sheppard Mullin Richter & Hampton LLP

CFPB Dismisses Two Actions Against Student Loan Trusts and Subprime Auto Lender 

The CFPB recently dropped two more lawsuits it brought under the Chopra administration—one involving a student loan securitization trust and the other regarding a subprime auto finance company. Both lawsuits included...more

Orrick, Herrington & Sutcliffe LLP

New York attorney general proposes bill against unfair, deceptive and abusive practices

On March 13, New York Attorney General Letitia James announced proposed legislation to strengthen the state’s consumer protection framework by expanding enforcement powers beyond deceptive acts and practices to also include...more

Sheppard Mullin Richter & Hampton LLP

CFPB Drops Two More Major Lawsuits 

The CFPB has recently dismissed two more enforcement actions—one against a major credit reporting agency and another against a lease-to-own financing provider. Both lawsuits involved allegations of abusive, unfair, and...more

Venable LLP

A Primer on State Consumer Financial Regulation: What Businesses Need to Know Now

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The landscape of consumer financial services is shifting, driven by a broader deregulatory trend at the federal level. In this environment, companies must still address federal consumer financial law compliance and navigate a...more

Troutman Pepper Locke

2024 Consumer Financial Services Year in Review and A Look Ahead

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We are pleased to share our annual review of regulatory and legal developments in the consumer financial services industry. With active federal and state legislatures, consumer financial services providers faced a challenging...more

Hudson Cook, LLP

CFPB Bites of the Month - 2024 Annual Review - Nondiscrimination and Military Protection Law

Hudson Cook, LLP on

In this article, we share a timeline of our monthly "bites" for 2024 applicable to consumers protected by nondiscrimination and military protection laws. 2025 will likely bring more of the same, particularly in the area of...more

Troutman Pepper Locke

CFPB Releases Supervisory Highlights Focusing on Student Loan Practices

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On December 16, the Consumer Financial Protection Bureau (CFPB or Bureau) released a special edition of its Supervisory Highlights, detailing a range of activities identified by CFPB examiners across the student loan...more

Hudson Cook, LLP

Technical Violations of State Collection Practices Laws Can Lead to Class Action Liability

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If you are reading this article, you are likely aware that a creditor collecting its own debts in its own name is not a "debt collector" under the federal Fair Debt Collection Practices Act ("FDCPA") or its implementing rule,...more

Cooley LLP

CFPB Report Highlights Collection Practice Concerns, Contains Novel UDAAP Theories

Cooley LLP on

On July 2, 2024, the Consumer Financial Protection Bureau (CFPB) released a new edition of Supervisory Highlights, with a particular focus on account management and collection practices across auto loans, student loans and...more

Hudson Cook, LLP

CFPB Bites of the Month - 2023 Annual Review - Debt Collection

Hudson Cook, LLP on

In this article, we share a timeline of our monthly "bites" for 2023 applicable to debt collection. If debt collection in 2023 had a theme it would be medical debt....more

Ballard Spahr LLP

CFPB issues annual FDCPA report; FTC issues annual letter on debt collection to CFPB (UPDATED)

Ballard Spahr LLP on

The CFPB has issued its annual Fair Debt Collection Practices Act report covering the CFPB’s debt collection activities in 2022.  The report incorporates information from the FTC’s most recent annual letter to the CFPB...more

Davis Wright Tremaine LLP

October 2023 UDAAP Bulletin

The following document provides a monthly roundup summarizing enforcement actions, guidance, rulemakings, and other public statements from the Consumer Financial Protection Bureau and the Federal Trade Commission regarding...more

Alston & Bird

Oh Snap! CFPB Sues Fintech Company under CFPA and TILA

Alston & Bird on

A&B Abstract: On July 19, 2023, the Consumer Financial Protection Bureau (CFPB) sued a Utah-based fintech company and several of its affiliates (the Company) for allegedly deceiving consumers and obscuring the terms of its...more

Sheppard Mullin Richter & Hampton LLP

Latest CFPB Supervisory Highlights Detail UDAAPs Across Range of Areas

On July 26, the CFPB released its Summer 2023 Supervisory Highlights reporting unfair, deceptive, and abusive acts or practices (UDAAPs) across a number of consumer financial products, including auto origination, auto...more

Ballard Spahr LLP

CFPB Summer 2023 Supervisory Highlights looks at auto origination and servicing, consumer reporting, debt collection, deposits,...

Ballard Spahr LLP on

The CFPB has released the Summer 2023 edition of Supervisory Highlights.  The report discusses the Bureau’s examinations in the areas of auto origination and servicing, consumer reporting, debt collection, deposits, mortgage...more

Troutman Pepper Locke

CFPB’s Summer Edition of Supervisory Highlights Focuses on Auto Lending/Servicing and Debt Collection Practices

Troutman Pepper Locke on

On July 26, the Consumer Financial Protection Bureau (CFPB or Bureau) released the summer edition of its Supervisory Highlights report, providing a high-level overview of alleged unfair, deceptive, or abusive acts or...more

Davis Wright Tremaine LLP

May 2023 UDAAP Bulletin

The following document provides a monthly roundup summarizing enforcement actions, guidance, rulemakings, and other public statements from the Consumer Financial Protection Bureau and the Federal Trade Commission regarding...more

Davis Wright Tremaine LLP

April 2023 UDAAP Bulletin

The following document provides a monthly roundup summarizing enforcement actions, guidance, rulemakings, and other public statements from the Consumer Financial Protection Bureau and the Federal Trade Commission regarding...more

Davis Wright Tremaine LLP

March 2023 UDAAP Bulletin

The following is a monthly roundup summarizing enforcement actions, guidance, rulemakings, and other public statements from the Consumer Financial Protection Bureau and the Federal Trade Commission regarding the prohibition...more

Hudson Cook, LLP

CFPB, State Regulators, and Courts Take Aim at Convenience Fees

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The first half of 2022 has seen a flurry of state and federal activity attempting to reign in "convenience fees"—fees charged by a creditor, debt collector, or third party to a consumer for making a payment via some means...more

BCLP

CFPB guidance on pay-to-pay fees impacts consumer loan agreements

BCLP on

Consumer debt collectors may not be permitted to charge consumers “convenience fees” for card payments, which the Consumer Financial Protection Board (the “CFPB”) calls “pay-to-pay” fees, unless the underlying loan agreement...more

Hudson Cook, LLP

CFPB, State Regulators, and Courts Take Aim at Convenience Fees

Hudson Cook, LLP on

The first half of 2022 has seen a flurry of activity at the state and federal level attempting to reign in "convenience fees" - fees charged by a creditor, debt collector, or third party to a consumer for making a payment via...more

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