Do “negative option” subscription services constitute unfair or deceptive practices under the Consumer Financial Protection Act (CFPA)? According to the Consumer Financial Protection Bureau (CFPB) in its recent circular,...more
Arizona Attorney General Mark Brnovich released opinion No. 22-(R22-011), concluding earned wage access (EWA) products that are fully non-recourse and no-interest are not “consumer lender loans” under Arizona law. Thus, those...more
On October 13, the Consumer Financial Protection Bureau (CFPB) released its 12th Annual Report to Congress on college credit card agreements. The report reviewed agreements and data covering the over 1.2 million student...more