It has been difficult to keep up with all of the changes that have been happening with Consumer Financial Protection Bureau (“CFPB”) lawsuits and interpretations because the CFPB has not been sending out press releases...more
Since our last report on what is happening with the Consumer Financial Protection Bureau (“CFPB”) during this administration, we have seen the Trump nominee for Director of the CFPB retracted from consideration in front of...more
As if the saga of litigation involving the Consumer Financial Protection Bureau (“CFPB”) and National Collegiate Master Student Loan Trusts (“NCSLT”) that has been going on since 2017 has not been protracted and complicated...more
We have been following closely developments with the Consumer Financial Protection Bureau (“CFPB”) and the Trump/Musk administration (see here and here), and while we have a few updates on the CFPB, Trump and Musk have taken...more
In the two weeks since our last update on what is happening with the Consumer Financial Protection Bureau ("CFPB"), the Trump administration has continued to take actions that make it seem as though they are intending to wind...more
We have been waiting to see how things are shaking out for the now-beleaguered Consumer Financial Protection Bureau (“CFPB”). A month out from Trump’s inauguration, we are still in a position of wondering if there will be a...more
We have reported on stablecoin regulation and legislation several times over the last few years, including on the most recent stablecoin legislation that appeared to have traction on a bi-partisan basis, the Lummis-Gillibrand...more
Since our last Cabinet News & Views issue on December 19, the Consumer Financial Protection Bureau (“CFPB”) has finalized yet another rule, this one addressing the circumstances under which medical bills should be removed...more
While many Federal agencies, including the prudential bank regulators, have decided to hold back moving forward with initiatives until after the inauguration in January, the Consumer Financial Protection Bureau ("CFPB") has...more
12/6/2024
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Credit Reporting Agencies ,
Data Brokers ,
Debt Collection ,
Fair Credit Reporting Act (FCRA) ,
Financial Institutions ,
Financial Markets ,
Financial Services Industry ,
Regulatory Oversight ,
Student Loans
On November 12, the Consumer Financial Protection Bureau (“CFPB”) published a report called “State Consumer Privacy Laws and the Monetization of Consumer Financial Data” that took an uneven look at how Federal financial...more
Checking in on what the Consumer Financial Protection Bureau (“CFPB”) has been up to for the last month, in case you missed it (and with some commentary)...more
10/10/2024
/ ATMs ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Credit ,
FDCPA ,
Financial Regulatory Reform ,
Financial Services Industry ,
Medical Debt ,
Mortgages ,
Regulation M ,
Regulation Z
On August 13th, the Consumer Financial Protection Bureau (“CFPB”) published a consumer advisory as well as an advisory opinion addressing “contracts for deeds”, which are also variously called a “bond for deed”, “land...more
On August 16th, the Consumer Financial Protection Bureau ("CFPB") Director, Rohit Chopra, published a blog post entitled “What Buy Now, Pay Later lenders are doing to be upfront with borrowers” that follows up on its proposed...more
In this report on the solar financing marketplace, which is characterized as an “Issue Spotlight”, the CFPB identifies four areas that they view to present risks to consumers. In the press release accompanying the report,...more
While we reported in our last Cabinet News & Views on the final rule regarding quality control standards for AVMs which will take effect one year after publication in the Federal Register (i.e., it has not yet been...more
On July 24th, the Consumer Financial Protection Bureau (CFPB) issued a new proposed rule “Streamlining Mortgage Servicing for Borrowers Experiencing Payment Difficulties”, with a comment period ending on September 9, 2024....more
7/29/2024
/ Chevron Deference ,
Comment Period ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Financial Regulatory Reform ,
Financial Services Industry ,
Mortgage Servicing Rules ,
Mortgages ,
Preemption ,
Proposed Rules ,
Regulatory Agenda
The banking regulators have not yet gone out on vacation, as demonstrated by this grab-bag of announcements, speeches, rules and guidance:
Acting Comptroller of the Office of the Comptroller of the Currency (OCC),...more
7/26/2024
/ Anti-Fraud Provisions ,
Banking Regulators ,
Banking Sector ,
Banks ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
NCUA ,
OCC ,
Regulatory Oversight ,
Risk Assessment ,
Risk Management
On June 6, 2024 federal regulators published a final rule addressing Quality Control Standards for Automated Valuation Models. This was a collaborative rulemaking effort that included regulators from the Office of the...more
6/28/2024
/ Algorithms ,
Appraisal ,
Automated Systems ,
Collateral ,
Consumer Financial Protection Bureau (CFPB) ,
FDIC ,
Federal Reserve ,
FHFA ,
Financial Institutions ,
Financial Services Industry ,
GSE ,
Mortgage-Backed Securities ,
Mortgages ,
NCUA ,
Secondary Markets ,
Securitization ,
Valuation
As we discussed in the fall over a series of articles (Part 1, Part 2, Part 3, and Part 4) and reported on further in January, the Consumer Financial Protection Bureau (“CFPB”) is on a mission to allow consumers to more...more
The UK’s Financial Conduct Authority (FCA) has reported its observations on firms’ market abuse surveillance arrangements in the May edition of Market Watch. The newsletter looks at a peer review of surveillance model testing...more
5/17/2024
/ Colorado ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
DIDMCA ,
FDIC ,
Financial Conduct Authority (FCA) ,
Financial Institutions ,
Financial Services Industry ,
Information Governance ,
Interest Rates ,
Loans ,
Surveillance ,
UK
As we reported in our Client and Friends memo last month, the Third Circuit published an opinion on March 19th finding that statutory trusts such as those that make up the National Collegiate Student Loan Trusts (the “NCSLT...more
In the Consumer Financial Protection Bureau’s (“CFPB’s”) most recent Supervisory Highlights, published on April 24th, the agency identified a wide variety of fees that were improperly charged to mortgage borrowers. As...more
On April 30, 2024, the Consumer Financial Protection Bureau (“CFPB”) published a report called “Price Complexity in Laboratory Markets” that concluded that the financial services industry should keep pricing for financial...more
The Consumer Financial Protection Bureau (“CFPB”) is engaged in a firestorm of tricky litigation these days. Some highlights, in addition to the Third Circuit’s NCSLT ruling we reported on previously:
With respect to the...more
On March 19, 2024, the Third Circuit handed down a decision that statutory trusts used as issuing entities for securitizations are considered “covered persons” for purposes of the Consumer Financial Protection Act ("CFPA"),...more