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The CFPB recently proposed two rules on its continuing war on so-called junk fees. The first rule, proposed on January 17, target’s bank overdraft programs. Currently, financial institutions that extend overdraft loans...more
With plaintiff attorneys seeing potential large dollar settlements and verdicts, along with increased regulatory scrutiny, banks need to review their overdraft practices. As noted by the American Bankers Association, banks...more
On August 4, 2017, the Consumer Financial Protection Bureau (CFPB) released four “prototype” model overdraft disclosure forms styled under its “Know Before You Owe” initiatives with a press release. The CFPB said the forms...more
Since opening its doors for business, behavioral economics has played a central role in the CFPB’s regulatory agenda. Behavioral economists posit that consumers are not rational decision makers and instead have certain...more