Earlier in January 2024, the CFPB continued its crackdown on what it decries as “junk fees,” releasing a Proposed Rule to curb overdraft fees. The Proposed Rule could have a significant effect on the nature, availability, and...more
2/7/2024
/ Banking Sector ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Enforcement Priorities ,
Fees ,
Financial Institutions ,
Overdraft Fees ,
Popular ,
Proposed Rules ,
Regulation Z ,
Truth in Lending Act (TILA)
One week after the CFPB published its proposed rule restricting overdraft fees, the CFPB proposed yet another rule prohibiting nonsufficient funds fees (NSF fees) on transactions like declined debit card purchases and...more
Consumer use of "buy now, pay later" (BNPL) products and programs has proliferated over the last few years. While federal oversight has not been extensive to date, new guidance from the Office of the Comptroller of the...more
The CFPB has issued a Circular addressing adverse action notification requirements and the proper use of the CFPB's sample forms provided in Regulation B when using artificial intelligence (AI) and complex credit models, and...more
9/25/2023
/ Adverse Action ,
Artificial Intelligence ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Discriminatory Lending Practices ,
ECOA ,
Fair Credit Reporting Act (FCRA) ,
Fair Lending ,
Financial Services Industry ,
Model Forms ,
Notice Requirements ,
Regulation B
As part of the continuing financial regulatory reform efforts following the 2023 bank failures, the FDIC, the OCC, and the Federal Reserve issued a proposed rule that would generally require large banks and thrifts with total...more
On August 8, 2023, the Federal Reserve released new guidance for supervised banking organizations on how they can engage in certain crypto-asset-related activities. With the release of the guidance, the Federal Reserve...more
Everyone—including fintechs, other non-bank companies, and associated individuals—that either partners with banks or seeks to provide alternatives to insured deposits must comply with the FDIC's deposit insurance advertising...more