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CFPB Reboots Policy Statements for No-Action Letters and Compliance Assistance Sandbox Approvals Days Before Administration Change

On January 10, 2025, the Consumer Financial Protection Bureau (CFPB) revived its policy statements on No-Action Letters (NALs) and Compliance Assistance Sandbox (CAS) Approvals. These unexpected changes come just days before...more

CFPB's Proposed Data Broker Rule: A Sweeping Rewrite of the Fair Credit Reporting Act Regulations That Will Be Left to New CFPB...

On December 3, 2024, the Consumer Financial Protection Bureau (CFPB) published its highly anticipated notice of proposed rulemaking (NPRM) that would regulate data brokers and the sale of Americans’ personal and financial...more

Open Banking Is Here: An Overview of Section 1033 of the Dodd-Frank Act

In a move that has been a long time in the making, the Consumer Financial Protection Bureau (CFPB) has finalized its comprehensive open banking rule. The rule implements Section 1033 of the Dodd-Frank Act and grants consumers...more

CFPB Crusade Continues: Mortgage Servicers and "Junk Fees"

Continuing its vigorous effort to eliminate so-called “junk fees,” and detailing other problematic mortgage servicer activities, the Consumer Financial Protection Bureau (CFPB) recently released its Spring 2024 Supervisory...more

CFPB Targets Mortgage Closing Costs as Junk Fees

On March 8, 2024, the CFPB issued a blog post signaling a new front in its focus on “junk fees”—mortgage closing costs. Notably, the CFPB suggests that title insurance, credit report and appraisal, origination, and other...more

A Closer Look at New York's Proposed Abusiveness Prohibition

In January, New York Governor Kathy Hochul introduced a budget bill that proposed the headline-grabbing Buy Now Pay Later licensing regime. Less attention has been given to another proposed provision: adding a prohibition on...more

FFIEC Issues Statement on Examination Principles Related to Valuation Discrimination and Bias in Residential Lending

On February 12, 2024, the Federal Financial Institutions Examination Council (FFIEC) issued a statement of principles that relate to valuation discrimination and bias for its member entities to consider in preparation for...more

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