As has been well-documented, the Consumer Financial Protection Bureau (CFPB or Bureau) is navigating a period of significant uncertainty. Just last week, the U.S. Court of Appeals for the District of Columbia vacated a...more
8/22/2025
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Dodd-Frank ,
ECOA ,
Financial Services Industry ,
Hiring & Firing ,
Layoffs ,
Mortgage Loan Originators ,
Mortgages ,
Open Banking ,
Payday Lending Rule ,
Regulatory Agenda ,
Rulemaking Process ,
Small Business ,
UDAAP
In a significant turn of events, the Consumer Financial Protection Bureau (CFPB or Bureau) has decided to initiate a new rulemaking process concerning its final rule on personal financial data rights under Section 1033 of the...more
7/30/2025
/ Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Privacy Rights ,
Data Privacy ,
Financial Institutions ,
Financial Services Industry ,
Open Banking ,
Personal Data ,
Rulemaking Process ,
Stays
On July 16, the Federal Reserve Board, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the federal banking agencies) jointly published a proposed rule...more
7/18/2025
/ Banks ,
Comment Period ,
Community Reinvestment Act ,
Consumer Financial Products ,
CRA ,
Equal Access to Credit ,
FDIC ,
Federal Reserve ,
Final Rules ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Lenders ,
Loans ,
Low-Income Issues ,
OCC ,
Proposed Rules ,
Regulatory Agenda ,
Regulatory Oversight ,
Regulatory Requirements
On July 14, the Office of the Comptroller of the Currency (OCC) issued Bulletin 2025-16, announcing the removal of references to disparate impact liability from the “Fair Lending” booklet of the Comptroller’s Handbook and...more
7/16/2025
/ Anti-Discrimination Policies ,
Banks ,
Borrowers ,
Consumer Financial Products ,
Deregulation ,
Discriminatory Lending Practices ,
Disparate Impact ,
Equal Access to Credit ,
Executive Orders ,
Fair Lending ,
Financial Regulatory Reform ,
Financial Services Industry ,
Handbooks ,
Lenders ,
OCC ,
Regulatory Authority ,
Regulatory Requirements ,
Trump Administration
n June 23, the Consumer Financial Protection Bureau (CFPB or Bureau) released an update to its 2015 report on Americans who did not have a credit record (credit invisibles) or who had insufficient credit history to have a...more
7/3/2025
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Protection Laws ,
Credit Reports ,
Credit Scores ,
Data Collection ,
Debt ,
Equal Access to Credit ,
Loans ,
Regulatory Reform ,
Student Loans
The Consumer Financial Protection Bureau (CFPB or Bureau) published in the Federal Register an interim final rule extending compliance dates for its 2023 small business lending rule under the Equal Credit Opportunity Act...more
6/19/2025
/ Compliance Dates ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Data Collection ,
ECOA ,
Filing Deadlines ,
Final Rules ,
Financial Institutions ,
Interim Final Rules (IFR) ,
Minority-Owned Businesses ,
Regulation B ,
Reporting Requirements ,
Rulemaking Process ,
Section 1071 ,
Small Business Loans ,
Women-Owned Businesses
On June 12, the U.S. District Court for the Northern District of Illinois denied the joint motion by the Consumer Financial Protection Bureau (CFPB or Bureau) and Townstone Financial, Inc. to vacate the Stipulated Final...more
6/17/2025
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
ECOA ,
Enforcement Actions ,
Financial Services Industry ,
First Amendment ,
Judicial Authority ,
Mortgage Lenders ,
Redlining ,
Regulation B ,
Settlement ,
Trump Administration ,
Vacated
On May 14, the Consumer Financial Protection Bureau (CFPB or Bureau) published a proposed rule to rescind amendments to its Procedures for Supervisory Designation Proceedings, originally adopted in 2022 and 2024. This...more
5/19/2025
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Financial Institutions ,
Financial Regulatory Reform ,
Non-Bank Lenders ,
Proposed Amendments ,
Proposed Rules ,
Public Comment ,
Regulatory Agenda ,
Regulatory Oversight ,
Rescission ,
Risk Management ,
Supervision
On May 1, the U.S. Court of Appeals for the Fifth Circuit dismissed the Consumer Financial Protection Bureau’s (CFPB or Bureau) appeal concerning the vacated amendments to its Unfair, Deceptive, or Abusive Acts and Practices...more
5/7/2025
/ Appeals ,
Banking Sector ,
Constitutional Challenges ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Discrimination ,
Discriminatory Lending Practices ,
ECOA ,
Enforcement Actions ,
Financial Institutions ,
Financial Services Industry ,
Regulatory Agenda ,
Regulatory Reform ,
UDAAP ,
Unfair or Deceptive Trade Practices
This week, the Consumer Financial Protection Bureau (CFPB or Bureau) released a memo to staff outlining its new supervision and enforcement priorities for 2025....more
4/18/2025
/ Banking Sector ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Discriminatory Lending Practices ,
Enforcement Actions ,
Fair Credit Reporting Act (FCRA) ,
Fair Lending ,
FDCPA ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Mortgages ,
Regulatory Reform ,
Regulatory Requirements ,
Supervisory Guidance ,
Trump Administration
The Consumer Financial Protection Bureau (CFPB or Bureau) agreed to vacate its controversial credit card late fee rule in a joint motion for entry of consent judgment filed in Chamber of Commerce of the United States of...more
4/16/2025
/ Administrative Procedure Act ,
CARD Act ,
Consent ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Cards ,
Final Rules ,
Financial Regulatory Reform ,
Financial Services Industry ,
Judicial Authority ,
Late Fees ,
Penalties ,
Regulatory Requirements ,
Statutory Violations ,
Vacated
On April 9, the House of Representatives passed two Congressional Review Act (CRA) joint resolutions aimed at nullifying certain Consumer Financial Protection Bureau (CFPB) rules finalized in the final days of the...more
4/14/2025
/ Congressional Review Act ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Final Rules ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Nullification ,
Overdraft Fees ,
Regulatory Reform ,
Regulatory Requirements
In a surprising turn of events, the Consumer Financial Protection Bureau (CFPB or Bureau) and Townstone Financial, Inc. (Townstone) have jointly moved to vacate the Stipulated Final Judgment and Order previously entered in...more
3/28/2025
/ Biden Administration ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Discriminatory Lending Practices ,
ECOA ,
Enforcement Actions ,
Financial Institutions ,
Financial Services Industry ,
First Amendment ,
Redlining ,
Regulatory Reform ,
Settlement Agreements ,
Stipulated Judgment ,
Trump Administration ,
Vacated
In a significant policy shift under the Trump administration, the new Federal Housing Finance Agency (FHFA) Director Bill Pulte issued an order on March 25, 2025 terminating special purpose credit programs (SPCPs) supported...more
3/28/2025
/ Banks ,
Consumer Financial Products ,
ECOA ,
Equal Access to Credit ,
Fair Housing Act (FHA) ,
Fannie Mae ,
FHFA ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Freddie Mac ,
GSE ,
Housing Market ,
HUD ,
Lenders ,
Mortgages ,
Regulatory Reform ,
Regulatory Requirements ,
Trump Administration
We are pleased to share our annual review of regulatory and legal developments in the consumer financial services industry. With active federal and state legislatures, consumer financial services providers faced a challenging...more
2/17/2025
/ Automotive Loans ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Enforcement Actions ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinTech ,
Regulatory Agenda ,
Regulatory Requirements ,
TCPA ,
UDAAP ,
Uniform Commercial Code (UCC)
In a dramatic series of events, the Consumer Financial Protection Bureau (CFPB or Bureau) has undergone leadership changes, signaling a significant shift in its regulatory approach. These changes began with the firing of...more
2/11/2025
/ Administrative Appointments ,
Constitutional Challenges ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Dodd-Frank ,
Financial Regulatory Reform ,
Financial Services Industry ,
Regulatory Agencies ,
Regulatory Agenda ,
Regulatory Reform ,
Trump Administration
In this third episode of the Year in Review series of The Consumer Finance Podcast, host Chris Willis is joined by Lori Sommerfield, a partner in Troutman Pepper Locke’s Consumer Financial Services Practice Group, to discuss...more
2/6/2025
/ Artificial Intelligence ,
Biden Administration ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Enforcement Actions ,
Fair Lending ,
Financial Regulatory Reform ,
Redlining ,
Section 1071 ,
Trump Administration ,
UDAAP
Hours before a scheduled hearing yesterday, the Consumer Financial Protection Bureau (CFPB or Bureau) filed an “Emergency Notice” in the U.S. Court of Appeals for the Fifth Circuit with respect to the ongoing litigation...more
2/4/2025
/ Administrative Procedure Act ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Data Collection ,
Dodd-Frank ,
Enforcement Actions ,
Final Rules ,
Financial Services Industry ,
Lending ,
Regulatory Requirements ,
Rulemaking Process ,
Section 1071 ,
Small Business ,
Small Business Loans ,
UDAAP
Last week, the Consumer Financial Protection Bureau (CFPB or Bureau) released its latest Supervisory Highlights report, focusing on the use of advanced technologies in credit scoring models. ...more
1/22/2025
/ Artificial Intelligence ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Scores ,
Data Privacy ,
Data Protection ,
Discriminatory Lending Practices ,
ECOA ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
Machine Learning ,
Regulatory Requirements ,
Risk Management
On January 7, the National Credit Union Administration (NCUA) released its supervisory priorities for 2025, outlining the key areas of focus for federally insured credit unions. This guidance is crucial for credit unions as...more
1/21/2025
/ Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Credit Cards ,
Credit Unions ,
Cybersecurity ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
Loans ,
NCUA ,
Overdraft Fees ,
Risk Management ,
Supervisory Guidance
On January 15, the Consumer Financial Protection Bureau (CFPB or Bureau) released a blog post highlighting the growing efforts by financial institutions to serve consumers with limited English proficiency (LEP). However,...more
This week, the Consumer Financial Protection Bureau (CFPB or Bureau) released its semiannual regulatory agenda, outlining its planned rulemaking initiatives. This agenda includes a mix of rules in the pre-rulemaking, proposed...more
12/19/2024
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
EFTA ,
Fair Credit Reporting Act (FCRA) ,
Financial Regulatory Reform ,
Financial Services Committee ,
Financial Services Industry ,
Overdraft Fees ,
PACE ,
Payment Processors ,
Regulatory Agenda ,
Regulatory Oversight ,
Rulemaking Process
Join host Chris Willis and guests Lori Sommerfield and Joseph Reilly in this episode of The Consumer Finance Podcast as they delve into the CFPB's recent study on differential treatment in small business lending. Discover the...more
On November 13, the Consumer Financial Protection Bureau (CFPB or Bureau) released a pilot study titled “Matched-Pair Testing in Small Business Lending Markets” highlighting what the CFPB believes were two statistically...more
11/15/2024
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Disparate Impact ,
Disparate Treatment ,
ECOA ,
Financial Institutions ,
Financial Services Industry ,
Race Discrimination ,
Section 1071 ,
Small Business ,
Small Business Loans
In a significant development, the Consumer Financial Protection Bureau (CFPB or Bureau) has finally reached a settlement with Townstone Financial, Inc. (Townstone) in the first redlining case brought against a nonbank...more
11/6/2024
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Discriminatory Lending Practices ,
ECOA ,
Enforcement Actions ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
Loan Applications ,
Mortgage Lenders ,
Race Discrimination ,
Redlining ,
Settlement