Amid recent technological advances in artificial intelligence and machine learning, on January 17, 2025, the CFPB issued its Winter 2025 Supervisory Highlights: Advanced Technologies Special Edition. This edition of...more
On July 11, 2024, the United States Court of Appeals for the Seventh Circuit issued its highly anticipated decision in Consumer Financial Protection Bureau v. Townstone Financial, Inc., et al. In this pivotal decision, the...more
“Although there may be other constitutional checks on Congress’ authority to create and fund an administrative agency, specifying the source and purpose is all the control the Appropriations Clause requires.” With these...more
Nearly two years ago, in April 2022, the CFPB issued a press release announcing its intent to start exercising its authority to examine non-bank financial services institutions that the CFPB has “reasonable cause to determine...more
Less than three years after the U.S. Supreme Court reviewed the CFPB’s appointment structure, the bureau again finds itself before the Court in what could prove the most consequential case for the financial services industry...more
As we all hit the grocery store for that forgotten cranberry sauce and send a few last urgent work emails, we hope everyone is able to be with friends and family this Thanksgiving. Here at Bradley, we are counting our...more
The Consumer Financial Protect Bureau (CFPB) issued a release on September 15, 2022, announcing its intent to issue additional interpretive guidance or rules to ensure “Buy Now, Pay Later” (BNPL) lenders comply with the same...more
Auto finance companies and others in the auto space should take note of a recent joint letter issued by the Consumer Financial Protection Bureau (CFPB) and Department of Justice (DOJ) about the legal protections under the...more
On July 27, 2022, the Consumer Financial Protection Bureau (CFPB) and the United States Department of Justice (DOJ) filed a complaint in the United States District Court for the Eastern District of Pennsylvania against...more
The Consumer Financial Protection Bureau (CFPB) issued an advisory opinion on June 29, 2022, clarifying its view as to the legality under the Fair Debt Collection Practices Act (FDCPA) of “convenience fees” for optional...more
As we have repeatedly discussed this year in our Financial Services Perspectives blog, the current leadership of the CFPB has placed a significant emphasis upon fair lending. Seemingly once a month, or even more frequently at...more
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
On Monday, the CFPB issued a press release announcing that it will start using its authority to examine non-bank financial services institutions that the CFPB has “reasonable cause to determine pose risks to consumers.” In...more
The current leadership of the CFPB has not been shy about highlighting the importance of fair lending—and it is becoming increasingly clear that fair lending and equity within the financial services industry is one of the...more
The Consumer Financial Protection Bureau (“CFPB”) issued a release on March 16, 2022 in order to announce changes to its supervisory operations with respect to discriminatory lending and servicing practices.
In its...more
On February 28, 2022, the CFPB released a Compliance Bulletin and policy guidance entitled “Mitigating Harm from Repossession of Automobiles.” In its bulletin, the CFPB sets forth the objective of reminding market...more
The Consumer Financial Protection Bureau (“CFPB”) released a blog post on February 4 warning of the possibility of discrimination in the appraisal process. The CFPB explained that, although appraisal discrimination based on...more
As 2021 came to an end, the Consumer Financial Protection Bureau (CFPB) released its 2021 Fall Supervisory Highlights, which cover the CFPB’s findings of examinations completed on the first half of the year. Though the CFPB’s...more
Earlier this month, California Gov. Gavin Newsom revealed plans to create a state version of the federal Consumer Financial Protection Bureau (CFPB) as part of the state’s proposed 2020-2021 budget. According to the...more
1/30/2020
/ Automotive Loans ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinTech ,
Governor Newsom ,
Proposed Regulation ,
Regulatory Agenda ,
Regulatory Oversight ,
Rulemaking Process ,
State Budgets ,
Unfair or Deceptive Trade Practices
Last November, Bradley’s Financial Services Perspectives team predicted that the Consumer Financial Protection Bureau’s (CFPB) then upcoming Notice of Proposed Rulemaking (NPRM) for the Does the New Debt Collection Rule Apply...more
6/14/2019
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Creditors ,
Debt Collection ,
Debt Collectors ,
Dodd-Frank ,
Enforcement ,
Enforcement Authority ,
FDCPA ,
NPRM ,
Proposed Rules ,
UDAAP
The Office of the Comptroller of the Currency announced, in a highly anticipated decision, that it would begin to consider special-purpose charter applications from fintech entities. This move, which has been the subject of...more
In 2013, the Consumer Financial Protection Bureau (CFPB) issued a bulletin on indirect auto lending that took the industry by storm. As we approach the five-year anniversary of the memo’s issuance, it’s valuable to reflect on...more
1/25/2018
/ Automotive Industry ,
Automotive Loans ,
Congressional Review Act ,
Consumer Financial Contracts ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Discrimination ,
Dodd-Frank ,
GAO ,
Lenders ,
Markups ,
Unfair or Deceptive Trade Practices
Auto lenders, like many private citizens, began 2017 curious as to what change the impending Trump administration would bring. In the landscape of government enforcement, however, the consensus amongst industry participants...more
1/22/2018
/ Automotive Industry ,
Automotive Loans ,
Car Dealerships ,
Congressional Review Act ,
Consumer Financial Contracts ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Dodd-Frank ,
Fair Credit Reporting Act (FCRA) ,
GAO ,
Lenders ,
Markups ,
RESPA ,
Subprime Loans ,
Trump Administration ,
Truth in Lending Act (TILA) ,
Unfair or Deceptive Trade Practices
One overarching certainty of federal debt collection law seems to be prolonged uncertainty over its appropriate scope. Is this scope about to change yet again? One recent bill called the Practice of Law Technical...more