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CFPB Takes Aim at Data Brokers: Proposed Rule Tightens Consumer Privacy Protections

On December 3, the CFPB announced a proposed rule to enhance oversight of data brokers that handle consumers’ sensitive personal and financial information. The proposed rule would amend Regulation V, which implements the Fair...more

Fifth Circuit Overturns OFAC Sanctions on Blockchain-based Privacy Technology

On November 26, the U.S. Fifth Circuit Court of Appeals overturned sanctions imposed by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) against a decentralized cryptocurrency mixing service (a...more

Federal Reserve Board Penalizes Two Banks for Compliance Deficiencies

On November 13, the Federal Reserve Board issued two cease and desist orders against a state-chartered bank and a bank holding company for alleged compliance deficiencies. The Federal Reserve Board first order was against...more

Federal Court Denies Request to Delay CFPB’s Small Business Lending Rule as Compliance Deadlines Approach

On November 15, the U.S. District Court for the Southern District of Texas overseeing the ongoing legal challenge to the CFPB’s Section 1071 small business lending rule, issued an order denying the plaintiff trade groups’...more

New CFPB Larger Participant Rule Boosts Oversight of Major Digital Payment Providers

On November 21, the CFPB announced the arrival of its finalized larger participant rule (the “Rule”) regulating nonbank companies offering digital funds transfer and payment wallet applications to consumers....more

CFPB Report Highlights Financial Data Protection Challenges

On November 12, the CFPB released a report analyzing federal and state-level privacy protections for consumer financial data. The current federal framework for financial data privacy relies on the Gramm-Leach-Bliley Act...more

CFPB Hits Telecom Giant with Fines for Alleged Exploitation of Incarcerated Consumers

On November 14, the CFPB entered into a consent order with a telecommunications company and its subsidiaries (collectively, the “company”) for allegedly withdrawing millions of dollars from over half a million consumer...more

Debt Collectors Push Back: Trade Group Sues CFPB Over New Medical Debt Collection Rules

On November 1, a debt collection trade group filed a complaint in federal court challenging an October 1 CFPB advisory opinion that warned debt collectors against seeking payment on unverified or potentially inflated medical...more

CFPB Penalizes Major Credit Union for Mishandled Online Banking Program Rollout

On October 31, the CFPB entered into a consent order with a Florida-chartered credit union for harming consumers in connection with the botched launch of a new online banking system, in violation of the Consumer Financial...more

California DFPI Rolls Out Registration Requirements for Debt Settlement, EWA, and Student Loan Relief Providers

On October 22, the California DFPI announced the state’s approval of registration regulations enacted under the CCFPL, which will require providers of (1) debt settlement services, (2) education financing, (3) income-based...more

CFPB Finalizes Personal Financial Data Rights Rule

On October 22, the CFPB announced the finalization of its Personal Financial Data Rights Rule under Section 1033 of the Dodd-Frank Act. The rule aims to bring the U.S. closer to an “open banking” framework by making it easier...more

CFPB Warns Employers Regarding FCRA Rules for AI-Driven Worker Surveillance

On October 24, the CFPB issued Circular 2024-06, which warns companies using third-party consumer reports, particularly surveillance-based “black box” or AI algorithmic scores, that they must follow the Fair Credit Reporting...more

OCC Issues Guidance on Refinance Risk in Commercial Lending

On October 3, the OCC issued Bulletin 2024-29, providing guidance for managing credit risk in connection with refinancing commercial loans.  The bulletin is directed at all banks with commercial loan portfolios, and...more

FTC Finalizes ‘Click to Cancel’ Rule

On October 16, the FTC announced that it has finalized its “click to cancel” rule, that will require sellers to make it much easier for consumers to cancel subscriptions. The final rule is part of the FTC’s ongoing review of...more

CFPB and DOJ Target Mortgage Lender for Alleged Discriminatory Redlining Practices

On October 15, the CFPB and the DOJ announced a settlement against a large mortgage lender for its alleged discriminatory redlining practices against residents of majority-Black neighborhoods in the greater Birmingham,...more

CFPB Supervisory Highlights Target Auto Finance Missteps

On October 7, the CFPB announced the release of a special edition of its Supervisory Highlights, focused on the agency’s most recent findings in auto financing. The CFPB’s Supervisory Highlights cover select examinations...more

Swipe Fee Saga Continues: OCC and Trade Groups Clash with Illinois AG

The banking industry’s efforts to challenge a new Illinois law banning interchange fees, also known as “swipe fees,” on tax and tip payments gained significant momentum when the OCC criticized the law as an “ill-conceived”...more

DFPI Cracks Down on Illegal Student Loan Debt Relief Practices

On September 30, a credit repair service provider and its owner were ordered to pay $31 million in consumer redress, and a $19 million civil money penalty, when a Massachusetts federal court granted summary judgment for the...more

Credit Repair Company Fined $50M for Misleading Consumers

On September 30, a credit repair service provider and its owner were ordered to pay $31 million in consumer redress, and a $19 million civil money penalty, when a Massachusetts federal court granted summary judgment for the...more

CFPB Issues Guidelines for Medical Debt Collection

On October 1, the CFPB issued an advisory opinion highlighting that debt collectors engaging in certain practices with respect to the collection of medical debts are strictly liable under the FDCPA and Regulation F....more

CFPB Revises Disclosure Requirements for Remittance Providers

On September 20, the CFPB announced a proposed rule which would make a minor yet noteworthy amendment to the guidelines for the disclosures that remittance providers are required to provide to consumers in connection with...more

CFPB Report Highlights Student Loan Struggles Facing Servicemembers

On September 24, the CFPB announced the release of its annual report on the most pressing financial concerns facing servicemembers. This edition highlights that servicemembers are encountering student debt-related...more

California Expands Debt Collection Protections for Small Businesses and Consumers

On September 24, California enacted a series of consumer protection laws, including three bills aimed specifically at restricting certain debt collection practices in connection with medical debt reporting, civil actions for...more

Senators Urge Regulators to Adopt Tighter Controls for BNPL

In a letter to the CFPB released on September 10, several Senate Democrats implored the Bureau to establish stricter guardrails for BNPL providers, arguing that consumer harm will occur absent action taken to reign in the...more

CFPB Targets Medical and Rental Debt Collection in 2024 Annual Report

On September 5, the CFPB issued its annual report on debt collection practices, detailing the Bureau’s efforts to enforce the Fair Debt Collection Practices Act (FDCPA). This year’s report focuses on improper practices in the...more

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