When using artificial intelligence (AI) or complex credit models, can lenders rely on the checklist of reasons provided in Regulation B sample forms for adverse action notices? According to today’s guidance issued by the...more
9/21/2023
/ Algorithms ,
Artificial Intelligence ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Applicants ,
Creditors ,
ECOA ,
Financial Institutions ,
Financial Services Industry ,
Lack of Specificity ,
Lenders ,
Machine Learning ,
Regulation B
On September 8, a federal court in the Eastern District of Texas granted summary judgment in favor of the U.S. Chamber of Commerce (Chamber) and several other trade associations, holding that the Consumer Financial Protection...more
9/12/2023
/ Administrative Procedure Act ,
Constitutional Challenges ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Financial Protection Bureau v Community Financial Services Association of America Ltd ,
Discriminatory Lending Practices ,
Dodd-Frank ,
ECOA ,
Financial Services Industry ,
Regulatory Agencies ,
Regulatory Authority ,
SCOTUS ,
UDAAP
A United States district court in Kentucky recently granted defendants’ motion to dismiss a case arising under the Fair Credit Reporting Act (FCRA) and Fair Debt Collection Practices Act (FDCPA) for lack of personal...more
8/8/2023
/ Consumer Financial Products ,
Consumer Reporting Agencies ,
Consumer Reports ,
Debt Collection ,
Fair Credit Reporting Act (FCRA) ,
Fair Lending ,
FDCPA ,
Financial Institutions ,
Financial Services Industry ,
Personal Jurisdiction ,
Tenants
On February 14, the Consumer Financial Protection Bureau (CFPB) released a report entitled Market Snapshot: An Update on Third-Party Debt Collections Tradelines Reporting. The report sought to examine trends in the reporting...more
Please join Consumer Financial Services Partner Chris Willis and his colleague Consumer Financial Services Partner David Anthony as they discuss the firm's seventh annual edition of the Consumer Financial Services Year in...more
On August 10, the Consumer Financial Protection Bureau (CFPB or Bureau) issued an interpretive rule, detailing when digital marketing providers for financial firms must comply with federal consumer financial protection laws....more
On December 16, the Consumer Financial Protection Bureau (CFPB) issued orders to five companies offering buy now, pay later (BNPL) products. BNPL programs are designed to allow consumers to purchase goods and to defer payment...more
The Consumer Bankers Association (CBA), a trade group of retail financial institutions, recently sent a letter to the Consumer Financial Protection Bureau (CFPB) director, requesting increased supervision of financial...more
On March 24, the Consumer Financial Protection Bureau (CFPB) provided the Consumer Response 2020 Annual Report (CFPB Report) to Congress. The CFPB Report reflects complaints submitted by consumers to the CFPB and analyzes...more
In January 2017, the Attorney General of Colorado filed two lawsuits against Marlette Funding LLC and Avant of Colorado LLC. Among other things, the lawsuits claimed that these two companies, as the online platforms for loans...more
8/25/2020
/ Amended Complaints ,
Closed-End Loans ,
Consumer Financial Products ,
Financial Services Industry ,
Interest Rates ,
Online Platforms ,
Preemption ,
Safe Harbors ,
Securitization ,
State Attorneys General ,
True Lender ,
Usury