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Fair Credit Reporting Act (FCRA) UDAAP

Goodwin

CFPB Files Suit Against "Rent-to-Own" Business Alleging Illegal Lending Practices

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​​​​​​​​On July 26, 2024, the Consumer Financial Protection Bureau (CFPB) announced that it filed a complaint against a point-of-sale financing company and its former chief executive officer in the United States District...more

Husch Blackwell LLP

CFPB Levels Up: Consumer Risks in Gaming Draws Regulatory Scrutiny

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If you thought virtual reality was free from real-world regulations, think again. On April 4, 2024, the CFPB released an Issue Spotlight that dives deeply into a realm the agency had not previously traversed—video games and...more

Troutman Pepper

More Privacy, Please – February 2024

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Editor’s Note: In recent regulatory and enforcement developments, the White House announced a new executive order aimed at strengthening cybersecurity at U.S. ports, and another executive order was issued to protect sensitive...more

Alston & Bird

CFPB Touts 2023 Greatest Hits and Casts a Line for Enforcement Hires

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What Happened? Earlier this week, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) released a blog post touting its 2023 successes in safeguarding “household financial stability” through the levying of fines and...more

Ballard Spahr LLP

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

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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

Hudson Cook, LLP

CFPB Bites of the Month - August 2023 - School Bells Ringing Loud and Clear, Vacation's Over, CFPB is Near

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In this month's article, we share some of our top "bites" for the prior month covered during the August 2023 webinar. Bite 1: CFPB Publishes Report on Employer-Driven Debt - On July 20, 2023, the CFPB published a...more

Troutman Pepper

CFPB's Section 1071 Final Rule (Part 3): Potential Problem Areas – The Consumer Finance Podcast

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Please join Troutman Pepper Partner Chris Willis and his colleagues Mark Furletti, Joe Reilly, and Christine Emello for the last installment of a special three-part series about the Consumer Financial Protection Bureau’s...more

Troutman Pepper

CFPB's Policy Statement on Abusiveness (Part 2) - The Consumer Finance Podcast

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Please join Troutman Pepper Partner Chris Willis and his colleagues Stefanie Jackman, Caleb Rosenberg, and Chris Capurso for the second installment of our special two-part series about the Consumer Financial Protection...more

Hudson Cook, LLP

CFPB Bites of the Month - 2022 Annual Review - Credit Cards

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In this article, we share a timeline of our monthly "bites" for 2022 applicable to the credit card industry. As evidenced by the timeline, federal regulators (primarily the CFPB) are beginning to renew their focus on credit...more

Bradley Arant Boult Cummings LLP

CFPB’s Release Highlights “Unlawful Auto Repossessions” and Failures to Conduct Reasonable Investigations on Disputed Debts

The Consumer Financial Protection Bureau (CFPB) issued a release on May 2, 2022, announcing the release of its Supervisory Highlights outlining identified consumer protection violations during the second half of 2021. In...more

Venable LLP

Buy-Now-Pay-Later: A 360 Degree Overview

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Buy-Now-Pay-Later (BNPL) products are taking center stage as a popular way for consumers to purchase goods or services now and pay for them over time through a short series of installments, often interest-free. Industry...more

Manatt, Phelps & Phillips, LLP

CFPB Will Enforce Laws Preventing the Collection/Reporting of Medical Debts Barred by the NSA

As part of the Biden administration’s focus on enforcement of the No Surprises Act (NSA), the Consumer Financial Protection Bureau (CFPB) has issued a bulletin (the Bulletin) indicating that it will closely review the...more

Morgan Lewis - All Things FinReg

CFPB Pans Credit Reporting Agency Consumer Complaint Handling

On January 5, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a report detailing consumer complaint deficiencies by the national credit reporting agencies (NCRAs). Specifically, the CFPB found that, in 2021,...more

Morrison & Foerster LLP

Financial Services Report - Winter 2021

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Welcome to the Financial Services Report, holiday style! Banks and non-banks alike started early this year with additions and changes to their regulator stockings. The Senate confirmed Rohit Chopra as the new CFPB Director....more

McGlinchey Stafford

When Is It A Firm Offer Of Credit?

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Creditors often ask when the Fair Credit Reporting Act’s (FCRA) rules relating to firm offers of credit apply. Do they apply when the creditor makes a prequalified offer? Does that change if the creditor makes a prescreened...more

BCLP

Changing “Buy Now Pay Later” Regulations & Considerations for Retailers

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On 2 February 2021, the FCA published its Review of the Unsecured Credit Market in the UK. The full title of the review is “The Woolard Review - A review of change and innovation in the unsecured credit market” (“the...more

Wiley Rein LLP

Wiley Consumer Protection Download (December 7, 2020)

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Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more

Manatt, Phelps & Phillips, LLP

CFPB Finds Multiple Consumer Finance Violations in National Bank’s Overdraft Practices

On August 20, the Consumer Financial Protection Bureau (CFPB) entered a consent order with a national bank over the sales and marketing practices for its optional overdraft service called Debit Card Advance (DCA). DCA...more

Ballard Spahr LLP

CFPB Settles Claims For Alleged UDAAP And FCRA Violations By Companies Issuing Contracts For Deeds

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The CFPB has entered into a consent order with three companies to settle the Bureau’s claims that the companies violated the Dodd-Frank UDAAP prohibition and the FCRA in connection with contracts for deeds that they issued...more

White & Case LLP

Consumer financial services: The road ahead: Auto finance

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In 2018, the CFPB continued to pay attention to the auto finance industry, with a particular focus on indirect (dealer-arranged) auto lenders and unfair or abusive loan servicing practices....more

Bradley Arant Boult Cummings LLP

CFPB Issues Second Consent Order under Acting Director Mulvaney

Security Group, Inc. and several of its wholly owned subsidiaries entered into a consent order with the Consumer Financial Protection Bureau (CFPB) in which it agreed to injunctive relief and to pay a $5 million penalty....more

Dorsey & Whitney LLP

Federal Court Orders Loan Servicer to Comply with CFPB’s CID Investigating Potential UDAAP and FCRA Violations

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On February 28, 2018, the U.S. District Court for the Western District of Pennsylvania granted a petition by the Consumer Financial Protection Bureau (“CFPB”) to enforce a civil investigative demand (“CID”) against a student...more

Ballard Spahr LLP

CFPB settles with consumer reporting agency for alleged UDAAP/FCRA violations

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The CFPB announced that it has entered into a consent order with Experian, a consumer reporting agency, for allegedly engaging in the deceptive marketing of credit scores in violation of the Consumer Financial Protection...more

Baker Donelson

How Does the CFPB View Private Label Servicing?

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As mortgage servicing compliance costs have risen year over year, lenders have looked for a way to decrease costs while retaining their customer visibility and brand awareness. In response to this demand, private label...more

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