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Dismantling the CFPB Officially on Hold and Other Bureau Updates

In a lengthy decision that highlighted the CFPB’s very public efforts to dismantle the CFPB from within, the District Court for the District of Columbia granted a motion for preliminary injunction designed to preserve the...more

Chaos and Confusion at the Bureau: Current Litigation Surrounding the Unwinding of the CFPB

As we discussed previously, the Consumer Financial Protection Bureau (CFPB) is facing a threat to its very existence, and this time, the call is coming from inside the house. After Acting Director Russ Vought and the...more

Litigation Byte (February 2025 Edition)

The District of Maryland rejected a plaintiff’s arguments that a debt collector’s verification of a debt in response to a letter refusing to pay, but disputing the debt, violated the cease communication directive under the...more

CFPB Under Trump: Leadership, Staffing, Legislative Developments

With an across-the-board freeze on all rulemaking, enforcement, and supervisory activities, and a potential mass lay-off in the works, the CFPB continues to make news. Here’s a recap of all that happened this past week at the...more

CFPB Under Siege: Legal Challenges, Leadership Changes, Congressional Moves

As we have highlighted previously (here and here), the Consumer Financial Protection Bureau (CFPB) has continued to undergo significant changes under the second Trump Administration. However, various interested parties have...more

FTC’s CARS Rule Vacated — What Finance Companies Need to Know

In a procedural decision, the U.S. Court of Appeals for the Fifth Circuit vacated the CARS Rule (officially, the Combatting Auto Retail Scams Trade Regulation Rule, sometimes known as the Vehicle Shopping Rule) which was...more

CFPB Upheaval Continues: An Update

As we highlighted on Monday, the Consumer Financial Protection Bureau (CFPB) is currently facing an existential crisis as the Trump Administration and DOGE work to dismantle large parts of the consumer watchdog. Here’s what...more

CFPB Under Trump: Internal and External Threats Continue to Mount

A new acting director. Freezes on any rulemaking, enforcement, or supervisory activities. Attempts to dismantle the department from within. In the span of a short forty-eight hours, the CFPB has faced possibly the greatest...more

Chopra Out. Bessent In (for Now). What’s Next at the CFPB?

As expected, the Trump administration formally terminated CFPB director Rohit Chopra over the weekend. And also as expected, President Trump used the Federal Vacancies Reform Act to appoint an acting CFPB Director—Treasury...more

Predicting The Lasting Changes CFPB May Face In 2025

With President-elect Donald Trump’s election victory and upcoming inauguration, big changes appear likely for the Consumer Financial Protection Bureau in 2025. As the bureau faces its third major leadership transition within...more

“Junk Fee” Revolution Continues: FTC Prohibits “Junk Fees” in Live-Event Ticketing and Short-Term Lodging Industries

Yesterday, the Federal Trade Commission (FTC) finalized its “Rule on Unfair or Deceptive Fees” (Junk Fees Rule) designed, the FTC noted, to prohibit bait-and-switch pricing and mandate clear and conspicuous price disclosures...more

The CFPB’s Credit Card Late Fee Rule Appears Doomed

On December 6, 2024, the United States District Court for the Northern District of Texas denied a motion by the Consumer Financial Protection Bureau (CFPB) to dissolve a preliminary injunction that had enjoined its Credit...more

Trump 2.0: Potential CFPB Changes in 2025

Former President Donald Trump emphatically won a second term in office, and with his election, sweeping changes appear in store for the Consumer Financial Protection Bureau (CFPB or Bureau). While President-elect Trump did...more

CFPB Proposes New Rules Aimed at “Streamlining” Mortgage Servicing

On July 10, 2024, the Consumer Financial Protection Bureau (CFPB or Bureau) proposed a rule it says will streamline mortgage servicing and the loss mitigation process. If enacted, the proposed rule would significantly revise...more

CFPB Warns: “Unlawful” or “Unenforceable” Terms in Form Contracts Can Violate CFPA

On June 4, 2024, the Consumer Financial Protection Bureau (CFPB) issued a Circular warning companies that the inclusion of “unlawful” or “unenforceable” terms in a form contract constitutes a deceptive act or practice in...more

CFPB Poised To Up The Ante After Supreme Court Victory

This is the second part of a two-part series on Consumer Financial Protection Bureau v. Community Financial Services Association of America. Read part one here. In what should not come as a surprise to anyone who observed...more

NJ District Court Underscores Limits of “Safe Harbor” Protection Under Regulation F

On May 7, 2024, the United States District Court for the District of New Jersey issued a decision holding that the use by a debt collector of the Model Form validation notice under Regulation F does not guarantee compliance...more

CFPB Supervisory Highlights Reflect Continued Emphasis on “Junk Fees”

On April 24, 2024, the Consumer Financial Protection Bureau (CFPB) released the latest edition of its Supervisory Highlights, this time targeting so-called “junk fees” in the mortgage servicing industry. According to the...more

CFPB’s So-Called “Junk Fees” Revolution Targets Residential Mortgage Loan Closing Costs

On March 8, 2024, the Consumer Financial Protection Bureau (CFPB) announced it was seeking public input on so-called “junk fees” incurred as part of the closing process for residential mortgage loans. The residential...more

“Junk Fee” Revolution Continues: CFPB Issues Final Rule Limiting Late Fees on Credit Cards

Tuesday, the Consumer Financial Protection Bureau (CFPB) issued a Final Rule capping most credit card late fees at $8. The CFPB believes its new rule may save consumers more than $10 billion a year in late fee charges for an...more

Chevron Deference is on Thin Ice

On Wednesday, January 17, 2024, the Supreme Court heard oral arguments in Loper Bright Enterprises, Inc. v. Raimondo and Relentless, Inc. v. Dep’t of Commerce, a pair of cases where a majority of the Justices made clear that...more

CFPB: Ignorance is No Excuse in FDCPA False, Deceptive, Misleading Violations

On January 2, 2024, the Consumer Financial Protection Bureau (CFPB) filed an amicus brief in the case of Carrasquillo v. CICA Collection Agency, Inc. where it argued that knowledge (i.e. “scienter”) of a violation of the Fair...more

Junk Fee Supervisory and Enforcement Activity Targets Auto Servicers

For almost two years, the Consumer Financial Protection Bureau (CFPB) has made combating so-called junk fees an agency priority, bringing multiple enforcement actions, undertaking supervisory activity, and collaborating with...more

Clues On High Court Outcome In CFPB Constitutionality Case

On October 3, the U.S. Supreme Court heard oral arguments in the Consumer Financial Protection Bureau v. Community Financial Services Association of America, the latest in a long line of cases targeting the constitutionality...more

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