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What the Future May Hold for the Consumer Financial Protection Bureau's Open Banking Rule

Will the Consumer Financial Protection Bureau’s (CFPB) recently promulgated open banking rule survive under the new Congress and incoming presidential administration? Two upcoming proceedings may hold the answer....more

Complying With the New "Open Banking" Regime: Primer and Fact Sheet

The Consumer Financial Protection Bureau (CFPB) finalized its “open banking” rule in late 2024. As required by Section 1033 of the Consumer Financial Protection Act, the CFPB promulgated the rule to require certain financial...more

Applying Loper Bright, the Seventh Circuit Holds that ECOA Protects Prospective Applicants

The Seventh Circuit recently issued one of the first appellate decisions to apply the US Supreme Court’s decision in Loper Bright Enterprises v. Raimondo, 144 S. Ct. 2244 (2024). In Loper Bright, the Supreme Court ended...more

Overview of the CFPB's Proposed Open Banking Rule and Final Industry Standard Setting Rule

The financial services and banking industry landscape continues to evolve in the face of new and emerging technologies. This phenomenon is especially prevalent in the sharing of consumer data between financial institutions...more

US Supreme Court Holds that the CFPB's Funding Structure Is Constitutional

On 16 May 2024, in a much-anticipated decision, the US Supreme Court held the funding mechanism for the Consumer Financial Protection Bureau (CFPB) is constitutional. The decision, Consumer Financial Protection Bureau v....more

CFPB Aiming to Oversee Digital Payments

In late 2023, the Consumer Financial Protection Bureau (CFPB) proposed a rule that would subject nonbank fintech companies to the CFPB’s authority. The CFPB articulated that it intends the rule to “level the playing field”...more

The Power of the Purse: Supreme Court Hears Argument on Constitutionality of CFPB Funding Structure

On 3 October 2023, the Court heard argument in Consumer Financial Protection Bureau v. Community Financial Services Association, Ltd., No. 22-448. In the matter, the Consumer Financial Protection Bureau (CFPB) challenges the...more

Revamped Relief

The CFPB’s Proposed Rule to Improve its No-Action Letter Program and to Establish a Regulatory Sandbox - Introduction - In December of 2018, the Senate confirmed Kathy Kraninger as the second Director of the Consumer...more

Change Order: The CFPB Previews Its Proposed FDCPA Regulations

The Consumer Financial Protection Bureau (“CFPB”) recently took the next step toward promulgating regulations under the Fair Debt Collection Practices Act (“FDCPA”) by releasing its “Outline of Proposals under Consideration...more

The Ninth Circuit Holds That Subsequent Debt Collectors Must Send FDCPA Validation-of-Debt Notices

The Ninth Circuit recently construed the Fair Debt Collection Practices Act (“FDCPA”) provision that requires a debt collector to send a validation-of-debt notice within five days of “the initial communication” with a...more

Payday Loans Under Attack: The CFPB's New Rule Could Dramatically Affect High-Cost, Short-Term Lending

On June 2, 2016, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) proposed a new rule under its authority to supervise and regulate certain payday, auto title, and other high-cost installment loans (the “Proposed...more

“Start Spreading the News”: Recent New York Regulations Impact Debt Collection and Default Servicing

Last month, the New York Department of Financial Services (“DFS”) finalized a regulation with a number of novel requirements affecting debt collection (including servicing delinquent loans) in New York. Previously, debt...more

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