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Illinois Federal Court Dismisses CFPB’s Case Against Townstone Financial, Finding ECOA Does Not Extend to Prospective Applicants

On February 3, an Illinois federal court dismissed a case brought by the Consumer Financial Protection Bureau (CFPB) against Townstone Financial, Inc., a Chicago mortgage lender, for alleged violations of the Equal Credit...more

New York Adopts Commercial Financing Transaction Disclosure Requirements

On February 1, the Superintendent of Financial Services Adrienne A. Harris announced that the New York State Department of Financial Services completed the process for adopting a new regulation relating to disclosure...more

CFPB Argues that Regulation E Applies to Pandemic Unemployment Benefits Paid Via Prepaid Cards

In a case involving the application of Regulation E (Reg. E) to certain prepaid cards, the Consumer Financial Protection Bureau (CFPB) submitted an amicus brief arguing that the error resolution procedures in Reg. E apply to...more

CFPB Proposes to Dramatically Cut Safe Harbor for Credit Card Late Fees

Today the Consumer Financial Protection Bureau (CFPB) published a proposed rule with request for public comment that would amend Regulation Z to: 1) decrease the safe harbor for credit card late fees to $8 and eliminate...more

New Mexico Enacts 36% APR Cap on Loans of $10,000 or Less

On January 1, 2023, House Bill 132 went into effect enacting a 36% annual percentage rate (APR) cap on loans up to $10,000 made under the New Mexico Bank Installment Loan Act of 1959 and the New Mexico Small Loan Act (SLA)....more

CFPB Issues Guidance on “Negative Option” Subscription Services

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

Colorado AG Announces Two More Settlements in GAP Refund Cases

On January 4, Colorado Attorney General Phil Weiser announced that his office had reached settlements with Bellco and Canvas credit unions which will provide $4 million in refunds of unearned guaranteed automobile protection...more

NJ Attorney General Reaches Settlement With Merchant Cash Advance Company Over Alleged Unfair and Deceptive Practices

On December 27, the New Jersey Division of Consumer Affairs (the Division) entered a consent order with Yellowstone Capital LLC (Yellowstone) and several related companies to resolve allegations that, in violation of the New...more

The OCC’s “Laser Focus” on Fair Lending

On November 14, Office of the Comptroller of the Currency (OCC) Senior Deputy Comptroller for Bank Supervision Policy Grovetta Gardineer delivered keynote remarks at the 2022 CRA & Fair Lending Colloquium where she discussed...more

FTC Fines Vonage $100M for “Junk Fees” and Using “Dark Patterns” to Make It Hard for Consumers to Cancel

The Federal Trade Commission (FTC) reached a $100 million settlement with Vonage over allegations that the internet phone service provider violated the FTC and Restore Online Shoppers’ Confidence Act (ROSCA) by adding “junk...more

FTC Seeks Public Comment on So-Called “Junk Fees”

On October 20, the Federal Trade Commission (FTC) issued an Advanced Notice of Proposed Rulemaking, seeking public comment on the harms stemming from what it characterizes as “junk fees,” i.e., fees that are allegedly...more

Federal Agencies Announce Increased Regulations Z and M Dollar Thresholds for Exempt Consumer Credit and Lease Transactions, and...

On October 13, the Consumer Financial Protection Bureau, the Federal Reserve Board, and the Office of the Comptroller of the Currency announced increased dollar thresholds used to determine whether certain consumer credit and...more

FTC and CFPB Provide Guidance on Buy Now, Pay Later Products After State AGs Urge CFPB for Oversight

In March 2022, state attorneys general provided comments to the Consumer Financial Protection Bureau (CFPB) concerning the CFPB’s inquiry into companies that offer consumers the opportunity to divide the cost of their...more

Chambers of Commerce and Banking Groups File Suit Against CFPB for Overstepping Its Authority With UDAAP Exam Manual Amendment

On September 28, the U.S. Chamber of Commerce (Chamber), together with the Longview Chamber of Commerce, American Bankers Association, Consumer Bankers Association, Independent Bankers Association of Texas, Texas Association...more

FTC Report Highlights Evolving Dark Patterns and Signals Increased Enforcement

The Federal Trade Commission (FTC) recently released a Bringing Dark Patterns to Light report, detailing the rise in sophisticated “dark patterns” that the FTC asserts are designed to trick and trap consumers. As the FTC’s...more

CFPB Signals Increased Regulation of Buy Now, Pay Later Products

After analyzing public feedback, as well as information gathered from the five providers of Buy Now, Pay Later (BNPL) products, the Consumer Financial Protection Bureau (CFPB) issued a report, making it clear that the CFPB...more

Registration Begins Under Utah’s Commercial Financing Registration Act

As we previously posted here, in March, Utah enacted its Commercial Financing Registration and Disclosure Act (CFRDA), requiring commercial financing providers to register with the Utah Department of Financial Institutions...more

CFPB Rules Digital Marketers Must Comply with Consumer Financial Protection Laws

On August 10, the Consumer Financial Protection Bureau (CFPB or Bureau) issued an interpretive rule, detailing when digital marketing providers for financial firms must comply with federal consumer financial protection laws....more

FHFA Establishes Office of Financial Technology and Issues RFI on Fintech in Housing Finance

On July 19, the Federal Housing Finance Agency (FHFA or the Agency) announced the establishment of the Office of Financial Technology to serve as a source of information, Agency support in addressing emerging risks, and...more

7/20/2022  /  Banking Sector , FHFA , FinTech , Mortgages

CFPB Agrees to March 31, 2023 Deadline for Final Rule Under Section 1071

The Consumer Financial Protection Bureau (CFPB or Bureau) agreed to a March 31, 2023 deadline to issue a final rule under Section 1071 of Dodd-Frank. Section 1071 amended the Equal Credit Opportunity Act (ECOA) to impose...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

DOJ Files Lawsuit Against Meta and Outlines Proposed Settlement Structure Over Allegedly Discriminatory Housing Advertising...

On June 21, the Department of Justice (DOJ) filed a lawsuit and a settlement framework with Meta Platforms, Inc. (previously known as Facebook) to resolve allegations that Meta’s advertising placement algorithms discriminate...more

California Approves Final Commercial Financing Disclosure Regulations and Sets Compliance Deadline

On June 9, California’s Office of Administrative Law approved commercial financing disclosure regulations (Regulations) which require consumer-like disclosures for certain commercial financing products such as small business...more

FTC Revisiting Key Digital Advertising Guidance

On June 3, the Federal Trade Commission (FTC) published a request for information that could form the basis for a major update of its digital advertising guidance. The FTC’s most recent digital advertising guidance is its...more

CFPB Releases a Warning — But No Helpful Guidance — on Machine Learning Model Adverse Action Notices

On May 26, the Consumer Financial Protection Bureau (CFPB or Bureau) announced that federal anti-discrimination law requires companies to explain to applicants the specific reasons for denying an application for credit or...more

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