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A Sneak Peek in the Consumer Financial Services Year in Review and a Look Ahead - The Consumer Finance Podcast [Audio]

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

Second Circuit Holds No FCRA Violation When Dischargeability of Debt is a Legal Question

Should credit reporting agencies (CRAs) be held liable under the Fair Credit Reporting Act (FCRA) for alleged reporting inaccuracies that turn on legal disputes? According to the Second Circuit in a recent decision, the...more

CFPB Highlights Purported “Problems With Tenant Background Checks”

On November 15, the Consumer Financial Protection Bureau (CFPB) issued two reports, highlighting what the CFPB perceives to be forms of errors that frequently occur in tenant background checks and the impacts the CFPB...more

CFPB Focuses on Junk Fees, Credit Reporting, and COVID-19 Relief Funds in Latest Supervisory Highlights

On November 16, the Consumer Financial Protection Bureau (CFPB) released a new Supervisory Highlights report, focusing on the auto servicing industry, consumer reporting, mortgage servicing, and COVID-19 relief funds. The...more

CFPB Files Cert Petition Requesting Expedited Review of Fifth Circuit Decision Finding Funding Structure Unconstitutional

As discussed here, on October 19, a three-judge panel of the Fifth Circuit Court of Appeals held that the Consumer Financial Protection Bureau’s (CFPB) funding mechanism violates the appropriations clause because the CFPB...more

CFPB Warns CRAs and Furnishers of FCRA Liability for Failing to Conduct Proper Investigations

On November 10, the Consumer Financial Protection Bureau (CFPB) published a circular, stating that both consumer reporting agencies (CRAs) and furnishers may be held liable under the Fair Credit Reporting Act (FCRA) for...more

CFPB Calls Fifth Circuit Decision “Neither Controlling Nor Correct”

Unsurprisingly, defendants in two separate enforcements actions filed by the Consumer Financial Protection Agency (CFPB) have cited the Fifth Circuit’s recent decision in Community Financial Services Association of America,...more

Fifth Circuit Finds CFPB Funding Structure Unconstitutional

In a major decision released October 19, a three-judge panel of the Fifth Circuit Court of Appeals found the funding mechanism for the Consumer Financial Protection Bureau (CFPB or Bureau) to be unconstitutional....more

CPFB Issues Final Rule for Credit Reporting for Survivors of Human Trafficking

On June 23, the Consumer Financial Protection Bureau (CFPB) issued a final rule, prohibiting consumer reporting agencies (CRAs) from reporting adverse information resulting from human trafficking on survivors’ credit reports....more

Keeping Up With the Bureau Episode 2: FCRA Preemption Issues, Infringing State Laws, and the CFPB's Position [Audio]

Please join Consumer Financial Services Partner Kim Phan and her guests and colleagues Alan Wingfield and David Anthony in the second episode of a special four-part series on recent developments with the Consumer Financial...more

Banking Groups Challenge CFPB’s RFI on Customer Service

Banking trade groups are challenging a request for information (RFI) issued by the Consumer Financial Protection Bureau (CFPB) regarding customer service at large financial institutions. In a joint letter dated August 22, the...more

CFPB Rules Digital Marketers Must Comply with Consumer Financial Protection Laws

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

Hyundai Ordered to Pay $19 Million in Penalties in CFPB’s Largest Fair Credit Reporting Case Against an Auto Servicer

The Bureau of Consumer Financial Protection (CFPB) ordered Hyundai Capital America (Hyundai) to pay $19.2 million for allegedly providing inaccurate information to consumer reporting agencies, including, the CFPB alleged,...more

Citing Uptick in Complaints, CFPB Will Push Banks to Refund More Victims of Money Transfer Scams

As peer-to-peer money transfer services (or cash apps) become more popular, there has been an increase in the number of scams enticing consumers to transfer funds to fraudsters. The law currently provides that the banks that...more

Recent CFPB Advisory Opinion Puts Pay-to-Pay Fees in Crosshairs

“Convenience” fees charged to consumers for the use of certain debt payment options have come under increased scrutiny, as regulators have sought to limit charges and other back-end fees that may come as a surprise to...more

CFPB Urges States to Regulate Consumer Reporting, Weighing in on Limited FCRA Preemption of State Law

On June 28, the Consumer Financial Protection Bureau (CFPB) issued an interpretive rule, encouraging states to enact more laws regulating consumer reporting, arguing that states’ powers are only constrained in limited ways by...more

Is CFPB’s UDAAP/Discrimination Announcement at Risk Under SCOTUS Decision in West Virginia v. EPA?

When the Consumer Financial Protection Bureau (CFPB or Bureau) unveiled its UDAAP exam manual at the end of March 2022, announcing that it had decided to interpret the word “unfair” in Dodd-Frank to prohibit discrimination,...more

CFPB Targets Convenience Fees in Latest Advisory Opinion

On June 29, the Consumer Financial Protection Bureau (CFPB or Bureau) issued an advisory opinion focused on consumer debt collectors and the convenience fees they charge for some payments, such as online or by phone....more

CFPB Director Chopra Announces New Approach to Regulations

In a June 17 blog post, Consumer Financial Protection Bureau (CFPB or Bureau) Director Rohit Chopra announced that the CFPB intends to “move away from highly complicated rules” in favor of “simpler and clearer rules.” As part...more

CFPB Addresses Credit Reporting in Buy Now Pay, Later Market

In a blog post released June 15, the Consumer Financial Protection Bureau (CFPB) continued to show its interest in credit reporting by Buy Now, Pay Later (BNPL) lenders. Recognizing the importance of credit reporting to...more

CFPB Releases a Warning — But No Helpful Guidance — on Machine Learning Model Adverse Action Notices

On May 26, the Consumer Financial Protection Bureau (CFPB or Bureau) announced that federal anti-discrimination law requires companies to explain to applicants the specific reasons for denying an application for credit or...more

FTC and CFPB Join Forces on Amicus Brief Arguing That FCRA Does Not Distinguish Between Legal and Factual Inaccuracy

On May 5, the Consumer Financial Protection Bureau (CFPB or Bureau) and the Federal Trade Commission (FTC) together filed an amicus brief in an appeal pending before the Court of Appeals for the Second Circuit, Sessa v. Trans...more

CFPB Argues the FCRA Requires Furnishers to Investigate Legal Issues Raised in Consumer Disputes

On April 7, the Consumer Finance Protection Bureau (CFPB or Bureau) filed an amicus brief in an appeal, pending before the Court of Appeals for the Eleventh Circuit in which the Bureau argued that the Fair Credit Reporting...more

Facing CFPB Criticism, Credit Bureaus Dramatically Reduce Medical Debt Credit Reporting

On March 18, the three nationwide consumer reporting agencies — Equifax, Experian, and TransUnion (NCRAs) — announced plans to change how medical debt will be reported on credit reports. The joint measures will result in the...more

CFPB Massively Expands Enforcement of Anti-Discrimination Through UDAAP

On March 16, the Consumer Financial Protection Bureau (CFPB or Bureau) unveiled an enormous change to its fair lending philosophy that will have major ramifications for financial services providers of all types. In a press...more

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