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The FTC Gives the Merchant of Record Model a Paddling

The Federal Trade Commission (FTC) recently settled an enforcement action with Paddle.com, a U.K.-based payments company, and its U.S. subsidiary (“Paddle”). The settlement resolves claims against Paddle for violation of the...more

CFPB Reverses Course, Withdrawing “Unprecedented” EFTA Interpretation

Following a brief pause under new leadership, the Consumer Financial Protection Bureau (CFPB) has resumed activities, albeit significantly in retreat from the positions taken by the prior administration. In a case involving...more

CFPB Signals Continued Involvement in Litigation with State Attorneys General

While the Consumer Financial Protection Bureau (“CFPB”) may have halted certain operations, it is remaining active in certain litigation, including cases brought by multistate attorneys general. Recently, the CFPB signaled...more

AI Trends for 2025 - AI and Financial Services: Balancing Innovation with Regulatory Compliance

As the adoption of artificial intelligence (AI) continues to expand, the financial services industry is leveraging this technology in many ways. AI’s application in credit decision making has become increasingly prominent,...more

Leaning In: The CFPB Publishes Rule on Fees for Overdraft Services

On December 30, 2024, the Consumer Financial Protection Bureau (CFPB) published a final rule that may dramatically change the way that certain large financial institutions offer overdraft services to consumers. Under the...more

CFPB Continues to Challenge Bank Fees: CFPB Issues Proposals to Regulate Overdraft Services and to Prohibit NSF Fees

As part of its ongoing attack on bank fees, the Consumer Financial Protection Bureau (CFPB) has issued two proposed rules to regulate fees charged by banks: one on overdraft services, and one on nonsufficient funds fees. The...more

Take 2: CFPB Provides New Guidance About What Constitutes “Abusive”

On April 3, 2023, the Consumer Financial Protection Bureau (CFPB or “Bureau”) issued new guidance about what constitutes an abusive act or practice under the Consumer Financial Protection Act (the “Policy Statement”). This...more

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