Managing Borrower Expectations - In the immediate term, most Lenders are considering modifications that offer (usually on request only and subject to normal underwriting and credit review) a 60–90 day deferral of payments...more
Editors’ Note: The following is one part of DWT’s ongoing coverage of the 2017 CARD Act Report. Other parts include our prior PLA post The Consumer Credit Market: The CFPB’s 2017 CARD Act Report and a recent FSR webinar....more
On May 31, 2017, the Consumer Financial Protection Bureau (CFPB) issued its Monthly Complaint Report, this month complaints by consumer aged 62 and older. The CFPB drew its analysis of more than 103,100 complaints from its...more
On June 8, 2017, the Consumer Financial Protection Bureau (CFPB) held a Consumer Advisory Board (CAB) meeting, at which CFPB Director Richard Cordray discussed deferred-interest products. The CFPB also included in a press...more
Last week, the Consumer Financial Protection Bureau (CFPB) sent letters to the CEOs of several issuers of store brand credit cards warning of fairness and transparency concerns with deferred-interest promotions. The CFPB has...more
The CFPB has issued its March 2017 complaint report that highlights credit card complaints. The report also highlights complaints from consumers in Massachusetts and the Boston metro area. ...more
On March 10, 2017, the Consumer Financial Protection Bureau (CFPB or Bureau) published a Request for Information (2017 RFI) regarding the consumer credit card market. In accordance with Section 502(a) of the Credit Card...more
On Friday, the Consumer Financial Protection Bureau (CFPB) published a request for information about the credit card market. The CFPB uses responses to those requests, in conjunction with other data and research, to publish...more
The CFPB has issued another request for information about the credit card market that identifies significant new issues of CFPB interest. The request is intended to inform the CFPB’s biennial review of the credit card market...more
The addition of IRC Sec 457A effectively ended the ability of investment managers to defer the tax recognition of the carried interest in the investment manager’s offshore fund. Under IRC Sec 457A, hedge fund managers must...more
The CFPB recently issued its 2015 CARD Act report on the consumer credit card market (the “Report”). The Report cites a significant amount of data with respect to the credit card market, including regarding use – e.g., number...more
On December 3, 2015, the Consumer Financial Protection Bureau ("CFPB" or “Bureau”) released its second biennial report on the consumer credit card market (“Report”), as required by the Credit Card Accountability...more
The CFPB has entered into a consent order with Springstone Financial, LLC to settle charges that the company was responsible for alleged deceptive and misleading acts and practices in connection with enrolling consumers in a...more
The CFPB recently published a blog post to tell consumers what they “need to know” about deferred interest credit cards offered by health care providers. The CFPB states in the blog post that, because health care...more
In the wake of its discussion of deferred interest products in its October report on the Credit CARD Act, the CFPB announced an enforcement action against a provider of deferred interest health-care credit cards and its...more
Yesterday, the Consumer Financial Protection Bureau (“CFPB”) announced a consent order with GE Capital Retail Bank and its subsidiary CareCredit (collectively “CareCredit”) related to what the CFPB alleges were unfair and...more