Last week, the Consumer Financial Protection Bureau (CFPB or Bureau) filed a complaint against SoLo Funds, Inc., a fintech company operating a small-dollar, short-term lending platform. The CFPB alleges that SoLo Funds...more
5/22/2024
/ Annual Percentage Rate (APR) ,
Borrowers ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Enforcement Actions ,
Fair Credit Reporting Act (FCRA) ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinTech ,
Loans ,
Statutory Violations ,
Unfair or Deceptive Trade Practices
In this episode of Payments Pros, Josh McBeain and Chris Willis discuss the Consumer Financial Protection Bureau's (CFPB) proposed rule on overdraft fees. The rule, which only applies to large financial institutions with...more
As discussed here, last week the U.S. Supreme Court issued its long-awaited decision in Community Financial Services Association of America, Limited (CFSA) v. Consumer Financial Protection Bureau (CFPB or Bureau) holding that...more
5/20/2024
/ Banks ,
Constitutional Challenges ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Financial Protection Bureau v Community Financial Services Association of America Ltd ,
Dodd-Frank ,
Federal Funding ,
Final Rules ,
Financial Institutions ,
Financial Services Industry ,
SCOTUS ,
Section 1071
On May 10, a Texas federal court granted a preliminary injunction enjoining the Consumer Financial Protection Bureau (CFPB or Bureau) from implementing the credit card late fee rule, most recently discussed here. The court...more
This week, the Consumer Financial Protection Bureau (CFPB or Bureau) published an Issue Spotlight focusing on consumer complaints relating to credit card rewards programs. The report notes that credit card companies often...more
On May 3, the U.S. Court of Appeals for the Fifth Circuit entered an order denying the CFPB’s (CFPB) petition for a panel rehearing and effectively setting the stage for a long-awaited ruling on a preliminary injunction in...more
5/9/2024
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Credit Cards ,
Debt Collection ,
Final Rules ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Injunctive Relief ,
Late Fees ,
Petition For Rehearing ,
Preliminary Injunctions
On April 30, the U.S. Court of Appeals for the Fifth Circuit issued an order vacating the district court’s effective denial of the motion for a preliminary injunction filed by several trade groups, including the U.S. Chamber...more
In this episode of The Consumer Finance Podcast, Chris Willis is joined by colleague Jesse Silverman. They discuss the crucial steps fintech firms need to take to establish and maintain successful partnerships with banks....more
On Tuesday, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a procedural rule streamlining the designation proceedings for nonbank supervision based on a particular entity posing “risks to consumers.” As...more
In this episode of The Consumer Finance Podcast, Chris Willis is joined by David Dove, a partner in Troutman Pepper's RISE group. They discuss the legal and practical considerations for businesses looking to locate a facility...more
On April 5, the U.S. Court of Appeals for the Fifth Circuit issued an order effectively reversing the district court’s decision to transfer the lawsuit challenging the Consumer Financial Protection Bureau’s (CFPB or Bureau)...more
4/9/2024
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Credit Cards ,
Debt Collection ,
Final Rules ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Late Fees ,
Preliminary Injunctions ,
Regulatory Agenda ,
Unconstitutional Condition ,
Writ of Mandamus
On March 29, the Consumer Financial Protection Bureau (CFPB or Bureau) released its Consumer Response Annual Report, providing a high-level overview of the 1,657,600 consumer complaints received by the Bureau from January 1...more
4/5/2024
/ Annual Reports ,
Automotive Loans ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Consumer Reporting Agencies ,
Credit Cards ,
Debt Collection ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Fraud ,
Mortgages ,
Regulatory Agenda ,
Student Loans
On April 2, the U.S. Court of Appeals for the Fifth Circuit issued an order staying the district court’s decision to transfer the lawsuit challenging the Consumer Financial Protection Bureau’s (CFPB) credit card late fee rule...more
4/4/2024
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Credit Cards ,
Debt Collection ,
Final Rules ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Late Fees ,
Motion to Transfer ,
Preliminary Injunctions ,
Regulatory Agenda ,
Stays
Last week, the lawsuit challenging the Consumer Financial Protection Bureau’s (CFPB or Bureau) credit card late fee rule (Final Rule) was transferred from the U.S. District Court for the Northern District of Texas to the...more
4/1/2024
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Credit Cards ,
Debt Collection ,
Final Rules ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Late Fees ,
Preliminary Injunctions ,
Safe Harbors
On March 18, Rohit Chopra, Director of the Consumer Financial Protection Bureau (CFPB), submitted comments to the Appraisal Subcommittee (ASC) regarding its oversight of The Appraisal Foundation. Director Chopra, who serves...more
In this special crossover edition of The Consumer Finance Podcast and the Payments Pros podcast, Chris Willis is joined by Josh McBeain and Glen Trudel. They discuss the recent final credit card late fee rule issued by the...more
In this episode of The Consumer Finance Podcast, Chris Willis is joined by Partners Sheri Adler and Mary Weeks to discuss the recent uptick in SEC enforcement activity related to whistleblowers. They focus on the implications...more
On February 23, the Consumer Financial Protection Bureau (CFPB or Bureau) released an order, dated November 30, 2023, establishing supervisory authority over installment lender World Acceptance Corp. The CFPB found that it...more
In this final episode of The Consumer Finance Podcast Year in Review series, host Chris Willis is joined by Tim St. George, a key member of our Consumer Financial Services Litigation team. They discuss the significant...more
Join us for an enlightening episode of The Consumer Finance Podcast, where we dissect the intricate world of debt collection, reflecting on the past year and forecasting future trends. This episode, hosted by Chris Willis,...more
Join hosts Dave Gettings, Kim Phan, and Chris Willis in this special crossover episode of FCRA Focus and The Consumer Finance Podcast in the first installment of our Year in Review and a Look Ahead series. They are joined by...more
In this video Chris Willis, co-chair of the CFS Regulatory Practice, discusses our annual review of regulatory and legal developments in the consumer financial services industry. With active federal and state legislatures,...more
Please join Troutman Pepper Partners Chris Willis and Michael Lacy for a special inside look at our annual publication of the Consumer Financial Services Year in Review and Look Ahead. In our eighth year of publishing this...more
Late last month, the Revenue Based Finance Coalition (RBFC), a trade group of sales-based financing providers, filed a complaint in the U.S. District Court for the Southern District of Florida challenging the Consumer...more
1/18/2024
/ Administrative Procedure Act ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Protection Act ,
Data Collection ,
Dodd-Frank ,
ECOA ,
Final Rules ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Regulatory Agenda ,
Reporting Requirements ,
Section 1071
As discussed here, during the summer of 2023, Representative Roger Williams (R-Texas) and Senator John Kennedy (R-La.) introduced identical Congressional Review Act (CRA) resolutions in the U.S. House and Senate (H.J. Res. 66...more