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Nevada Passes Law Creating Licensing Requirements for Earned Wage Access Providers

On June 15, Nevada Governor Joe Lombardo signed SB 290 into law, which imposes licensing, reporting, examination, and other substantive requirements on providers of earned wage access (EWA) products. Specifically, the...more

Colorado Passes Legislation Seeking to Stop State-Chartered Banks from Preempting Colorado’s Usury Limit

As discussed here, in April 2023, Colorado introduced HB 1229 that proposed to limit certain charges on consumer loans and simultaneously opt Colorado out of sections 521-523 of the Depository Institutions Deregulation and...more

Financial Services Industry Groups Oppose CFPB’s Proposed “Fine Print” Registry

Financial services industry groups are staunchly opposing a proposal by the Consumer Financial Protection Bureau (CFPB or Bureau) to require supervised nonbank entities to provide information about their use of certain terms...more

Credit Acceptance and National Trade Associations Challenge the CFPB and NY AG’s Attempt to Disregard TILA and Regulate the...

On January 4, the Consumer Financial Protection Bureau (CFPB) and New York Attorney General (NY AG) filed a joint complaint in the U.S. District Court for the Southern District of New York against Credit Acceptance...more

Second Circuit Upholds CFPB’s Funding Structure

Yesterday, a three-judge panel of the Second Circuit Court of Appeals issued a unanimous opinion declining to follow the Fifth Circuit’s decision in Community Financial Services Association of America, Ltd. v. Consumer...more

CFPB Warns Student Loan Servicers About Collecting on Discharged Debt

On March 16, the Consumer Financial Protection Bureau (CFPB) released a compliance bulletin entitled Unfair Billing and Collection Practices After Bankruptcy Discharges of Certain Student Loan Debts. The compliance bulletin...more

CFPB Issues Analysis on Consumers of Buy Now, Pay Later Products

As we reported here, late last year, the Consumer Financial Protection Bureau (CFPB) signaled that it planned to increase scrutiny of the Buy Now, Pay Later (BNPL) industry and issued its first report about BNPL. Yesterday,...more

Supreme Court to Hear CFPB Funding Case

This morning the U.S. Supreme Court granted the Consumer Financial Protection Bureau’s (CFPB or Bureau) petition for certiorari in Community Financial Services Association of America Ltd. (CFSA) v. CFPB, a case that could...more

Community Financial Services Association of America Files Opposition to Certiorari and Cross Petition for Certiorari

As discussed here, on October 19, 2022 the Fifth Circuit Court of Appeals in Community Financial Services Association of America Ltd. (CFSA) v. Consumer Financial Protection Bureau (CFPB) held that the CFPB’s funding...more

CFPB Moves Forward With Proposed Rule Establishing Public Registry of Terms and Conditions in Form Contracts

As forecasted in its 2022 Fall Rulemaking Agenda discussed here, today the Consumer Financial Protection Bureau (CFPB) published a proposed rule with request for public comments that would require certain nonbank covered...more

State AGs With Opposing Objectives File Separate Amicus Briefs Urging Supreme Court to Grant Cert in CFPB Funding Appeal

As discussed here, on October 19, the Fifth Circuit Court of Appeals in Community Financial Services Association of America Ltd. (CFSA) v. Consumer Financial Protection Bureau (CFPB) held that the CFPB’s funding mechanism...more

CFPB Publishes Notice of Proposed Rulemaking Signaling Intent to Create Registry of Repeat Offenders

As a further reflection of its recent emphasis on “repeat offenders,” on December 12, the Consumer Financial Protection Bureau (CFPB) published a proposed rule with request for public comment that would require certain...more

Fourteen State Attorneys General File Amicus Brief In Support of Lawsuit by U.S. Chamber of Commerce Against the CFPB

Yesterday, 14 Republican attorneys general (AGs) filed an amicus brief in support of a lawsuit brought by the U.S. Chamber of Commerce and other co-plaintiffs against the Consumer Financial Protection Bureau (CFPB or the...more

CFPB Partners With Local Governments to Protect Consumers

On November 18, the Consumer Financial Protection Bureau (CFPB) published a blog post outlining its recent initiative to share consumer complaint data with cities and counties so they can, “increase their efforts to protect...more

CFPB Seeks Further Input on Shifting P2P Fraud Liability to Banks

In an October 27 letter, the American Bankers Association (ABA) expressed concern regarding a proposal currently being considered by the Consumer Financial Protection Bureau (CFPB) that would shift liability from consumers to...more

CFPB Examines Potential Impact of Student Loan Payment Reinstatement

On November 2, the Consumer Financial Protection Bureau (CFPB) released a blog post, exploring the potential impact of student loan payment reinstatement. The CFPB found that student loan borrowers are increasingly likely to...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

State Attorney General Calls on CFPB to Heed Fifth Circuit’s Ruling in Community Financial Services Association of America

In response to the Fifth Circuit’s ruling in Community Financial Services Association of America, Ltd. v. Consumer Financial Protection Bureau (CFSA) that the Consumer Financial Protection Bureau’s (CFPB) funding mechanism is...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

CFPB Focuses on Student Loans — Especially Those Made by Schools — in Latest Supervisory Highlights

On September 29, the Consumer Financial Protection Bureau (CFPB or Bureau) released a special edition of its Supervisory Highlights, focusing on student loan servicing. The report contained findings on federal student loan...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

US Chamber of Commerce Launches Campaign to Rein in CFPB

On June 28, the U.S. Chamber of Commerce (Chamber) launched a focused campaign to highlight what it describes as unlawful regulatory overreach by the Consumer Financial Protection Bureau (CFPB or Bureau) and, specifically,...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

Troutman Pepper’s Fintech Capabilities and Trending Issues Impacting Fintech Companies - The Consumer Finance Podcast [Audio]

Please join Troutman Pepper Partners Kim Phan and James Kim as they discuss the firm’s expanded capabilities in the fintech world, recent compliance issues for fintech companies, the CFPB’s dormant authority to supervise...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

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