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CFPB Issues FDCPA Proposed Rule: A Detailed Overview

On May 7, 2019, the Consumer Financial Protection Bureau (CFPB) released a much anticipated proposed rule regarding the Fair Debt Collection Practices Act (FDCPA). ...more

What to Do Now About the New CFPB Rule on Arbitration?

What to do now about the new CFPB rule on arbitration? (1) begin planning now and (2) begin actual preparation after the 60 days runs. Congress has 60 days after publication of the new CFPB rule to take action to stop the...more

Are Existing Agreements Governed by the New CFPB Arbitration Rule?

The Dodd Frank Act expressly provided that any CFPB rule on arbitration would not apply to existing contracts. 12 U.S.C. § 5518(d). Therefore, the CFPB rule released last week will only bar class action waivers for...more

CFPB Kills Class Action Waivers in Consumer Contracts and Makes Arbitration Public

The Consumer Financial Protection Bureau (CFPB) issued a rule yesterday prohibiting class action waivers in arbitration provisions of certain consumer contracts. The rule—to be codified at 12 C.F.R. § 1040—does far more than...more

SCOTUS’s FDCPA Opinion in Henson v. Santander: It’s Not Debt Collection When You Own It

Yesterday, the Supreme Court of the United States issued its opinion in Henson v. Santander Consumer USA, Inc.—Justice Gorsuch’s first as a Supreme Court Justice. The question presented was whether “individuals and entities...more

CFPB Single-Director Structure Deemed Unconstitutional

Yesterday—in PHH Corp. v. CFPB—the U.S. Court of Appeals for the District of Columbia (the “D.C. Circuit”) held that the single-director structure of the Consumer Financial Protection Bureau (“CFPB”) is unconstitutional,...more

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