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Policy Statement Consumer Financial Products

Husch Blackwell LLP

CFPB Reboots Policy Statements for No-Action Letters and Compliance Assistance Sandbox Approvals Days Before Administration Change

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On January 10, 2025, the Consumer Financial Protection Bureau (CFPB) revived its policy statements on No-Action Letters (NALs) and Compliance Assistance Sandbox (CAS) Approvals. These unexpected changes come just days before...more

Holland & Knight LLP

CFPB Keeps to Its Word by Issuing Additional Buy Now, Pay Later Guidance

Holland & Knight LLP on

purred by increased online and mobile app shopping during the COVID-19 pandemic, the Buy Now, Pay Later (BNPL) market has experienced higher growth and popularity as an innovative consumer finance offering, particularly for...more

Nutter McClennen & Fish LLP

Nutter Bank Report: April 2024

The CFPB has issued a policy statement that provides an analytical framework for identifying what constitutes an abusive act or practice under the Consumer Financial Protection Act of 2010 (CFPA). The new guidance published...more

Troutman Pepper Locke

Will Resiliency Carry the Digital Asset Sector Through 2024?

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In 2023, the digital asset industry demonstrated remarkable resilience amidst significant challenges, including the dissolution of several digital asset financial services companies, numerous bank failures, and a $4.7 billion...more

Hudson Cook, LLP

Spotlight on "Abusive" Practices - The CFPB's Policy Statement and What It Means for Your Business

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On April 3, 2023, the Consumer Financial Protection Bureau issued a policy statement on "abusive" practices. While this is the second time the CFPB has issued a policy statement on abusiveness, the significance of this policy...more

Morrison & Foerster LLP

Take 2: CFPB Provides New Guidance About What Constitutes “Abusive”

On April 3, 2023, the Consumer Financial Protection Bureau (CFPB or “Bureau”) issued new guidance about what constitutes an abusive act or practice under the Consumer Financial Protection Act (the “Policy Statement”). This...more

Eversheds Sutherland (US) LLP

CFPB issues policy statement on abusiveness with a focus on digital interaction

On April 3, the CFPB issued a policy statement intended to provide “a framework to help federal and state enforcers identify when companies engage in abusive conduct.” Conduct violates the abusiveness standard when it either:...more

Akerman LLP

CFPB Issues New Policy Statement on Abusive Acts or Practices

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On April 3rd, the Consumer Financial Protection Bureau issued a new Policy Statement ("Policy") providing an analytical framework to identify "abusive" conduct. This is the second time the CFPB has issued a Policy Statement...more

Orrick, Herrington & Sutcliffe LLP

CFPB’s Policy Statement Attempts to Clarify “Abusive” Conduct

On April 3, 2023, the Consumer Financial Protection Bureau (CFPB) issued a policy statement on its interpretation of the prohibition on abusive conduct under the Consumer Financial Protection Act (CFPA). Director Rohit Chopra...more

Orrick, Herrington & Sutcliffe LLP

CFPB defines abusive conduct under the CFPA

On April 3, the CFPB issued a policy statement containing an “analytical framework” for identifying abusive conduct prohibited under the Consumer Financial Protection Act. The Bureau broadly defines abusive conduct as...more

Venable LLP

CFPB Knows Best: Consumer Financial Protection Circulars Will Explain How CFPB Intends to Enforce Federal Consumer Financial Law

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The CFPB has begun issuing Consumer Financial Protection Circulars to the government agencies responsible for co-enforcing federal consumer financial law. The Circulars are policy statements that outline how the CFPB intends...more

Jenner & Block

CFPB Adds “Discrimination” to its “Unfair, Deceptive, or Abusive Acts and Practices” (UDAAP) Examination Guidance

Jenner & Block on

On March 16, 2022, the Consumer Financial Protection Bureau (CFPB) announced its intent to address discrimination as an “unfair practice” under the Consumer Financial Protection Act (commonly known as Dodd-Frank)....more

Akerman LLP

CFPB Finalizes COVID-19 Amendments Regarding Foreclosure Protections for Borrowers

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On June 28, 2021, the Consumer Financial Protection Bureau (CFPB) issued a final rule to amend the mortgage servicing rules in Regulation X, which implements the Real Estate Settlement Procedures Act, to provide additional...more

Goodwin

CFPB Seeks to Hold Mortgage Servicers Accountable, and Establish New Mechanisms for Protecting Borrowers, Against Forthcoming...

Goodwin on

This month the Consumer Financial Protection Bureau (CFPB) doubled-down on its earlier warning that the end of 2021 could see widespread foreclosures as COVID-19-related protections expire, by issuing guidance to mortgage...more

Bricker Graydon LLP

CFPB issues warning to mortgage servicers

Bricker Graydon LLP on

On April 1, 2021, acting Director of the Consumer Financial Protection Bureau (CFPB), David Uejio, fired a shot across the bow of mortgage servicers in the form of a Compliance Bulletin and Policy Guidance (Bulletin)....more

Akerman LLP

CFPB Rescinds Temporary COVID Policy Statements

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On April 1, 2021, the Consumer Financial Protection Bureau rescinded seven policy statements issued between March 26 through June 3, 2020 that provided temporary relief from certain regulatory obligations during the COVID-19...more

Goodwin

PPP Extended; CFPB Revokes Pandemic-Related Regulatory Relief

Goodwin on

In This Issue. President Biden signed a bill extending the Small Business Administration’s (SBA) Paycheck Protection Program (PPP) through May 31, 2021; the Consumer Financial Protection Bureau (CFPB) announced the rescission...more

Akerman LLP

CFPB Rescinds Policy Statement Regarding Abusiveness

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On March 11, 2021, the Acting Director of the Consumer Financial Protection Bureau rescinded the CFPB's January 24, 2020 policy statement that had established certain restrictions on how the CFPB will apply its abusiveness...more

Morgan Lewis - All Things FinReg

Elections Have Consequences: Biden’s CFPB Leadership Rescinds Previous Administration Self-Fencing of Enforcement Authority

The Consumer Financial Protection Bureau (CFPB or Bureau) issued a Statement of Policy (Statement) on March 8 making it clear that going forward it will exercise its full authority to penalize covered persons found to have...more

Morrison & Foerster LLP

Stop; Reverse That: CFPB Rescinds Abusiveness Policy Statement

On March 11, 2021, the Consumer Financial Protection Bureau (CFPB or “Bureau”) issued a Rescission of Statement of Policy rescinding its January 24, 2020 Policy Statement regarding the prohibition on abusive acts or practices...more

Ballard Spahr LLP

CFPB issues policy statement on applications for early termination of administrative consent orders

Ballard Spahr LLP on

The CFPB has issued a “Statement of Policy on Applications for Early Termination of Consent Orders.” The statement is applicable as of today....more

Goodwin

Financial Services Weekly Roundup: Madden Fix/Valid When Made Rule Faces New Challengers

Goodwin on

In the News. On the heels of a lawsuit challenging the Office of the Comptroller of the Currency’s (OCC) recently issued Madden fix/valid when made rule, eight state attorneys general filed suit challenging a similar rule...more

Morgan Lewis - All Things FinReg

CFPB Announces New Steps to Prevent Consumer Harm

The Consumer Financial Protection Bureau (CFPB or Bureau) announced on March 6 three steps designed to advance its strategy on one of its key priorities: preventing consumer harm. ...more

Jones Day

The CFPB's Policy Statement Concerning the Meaning of "Abusiveness"

Jones Day on

The Situation: For the past 10 years, regulated entities and others have sought more definition concerning the nature and scope of claims the Consumer Financial Protection Bureau ("CFPB") might bring alleging "abusive"...more

Moore & Van Allen PLLC

A Small Step Toward Clarity? The CFPB Issues Policy Statement on “Abusiveness” Standard

Moore & Van Allen PLLC on

On January 24, 2020 the CFPB issued a long-awaited policy statement about the meaning of “abusiveness” in the Bureau’s frequently-used enforcement weapon, 1031(d) of the Dodd-Frank Act, commonly referred to as UDAAP. Unlike...more

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