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CFPB Seeks to Fundamentally Alter the Credit Reporting Process and Use of Public Data

On Sept. 21, 2023, the Consumer Financial Protection Bureau (CFPB) officially announced it is considering a rulemaking to address several consumer reporting topics under the Fair Credit Reporting Act (FCRA). Under the process...more

CFPB Unfairness Authority Limited by Court

Organizations in many instances no longer must spend money on compliance with the Consumer Financial Protection Bureau’s (CFPB) interpretation of its UDAAP authority announced in the March 2022 update to its Supervision and...more

Briefs Pour in as the CFPB’s Fate Hangs By a Thread

On July 14, 2023, the U.S. Supreme Court announced it would hear oral arguments in Consumer Financial Protection Bureau (CFPB) v. Community Financial Services Association of America (CFSA) on October 3, 2023. The court will...more

Colorado Privacy Act Takes Effect July 1

Colorado’s new comprehensive consumer privacy law, the Colorado Privacy Act (CPA), will take effect on July 1, 2023. Earlier this year, the Colorado Attorney General’s Office (“AG”) finalized its yearlong rulemaking process,...more

SEC Sues Coinbase: What Does It Mean For Other Crypto Companies?

After months of bad news for cryptocurrency, the Securities and Exchange Commission’s latest moves could be apocalyptic for the industry. We previously wrote about the SEC’s Wells Notice issued to Coinbase in March 2023. A...more

Jaw-Dropping Development at the SEC: Coinbase Receives Wells Notice

In the latest stunning development in crypto policy, one of the industry’s largest exchanges is facing potential charges from the SEC. Coinbase, Inc. said on March 23, 2023, that it had received a “Wells Notice” from the U.S....more

SVB and Signature Bank Fallout: How to Assess Your Legal Risk and Next Steps

The failure of two large banks in California and New York and the historic fallout has left a quagmire of unanswered questions and crises for businesses who had worked with them—and those who may feel the ricocheting effects...more

FTC Extends Comment Deadline on Noncompete Rule

Comments on the Federal Trade Commission’s proposed noncompete clause rulemaking will now be accepted until April 19. The FTC voted 4-0 yesterday to extend the public comment window by roughly 30 days; it was initially set to...more

Supreme Court Agrees to Hear CFPB Constitutionality Case

On Monday, the U.S. Supreme Court announced that it has agreed to review the Fifth Circuit’s decision in Consumer Financial Protection Bureau (CFPB) v. Community Financial Services Association of America (CFSA). The decision...more

Biden Administration Announces Crackdown on “Junk Fees”

On Feb. 1, 2023, the Biden administration released a fact sheet describing actions taken by the White House that continue a focus on so called “junk fees.” The announcement, which was done along with several independent...more

The Federal Trade Commission Takes Unusual Steps to Shore Up Support on Proposed Rule to Ban Noncompete Clauses

The Federal Trade Commission (FTC) announced it will host a public forum on Thursday, Feb. 16 to examine the FTC’s Notice of Proposed Rulemaking (Proposed Rule) to prohibit businesses from imposing noncompetes on their...more

CFPB Proposes Big Brother Tactics for Consumer Contracts

On Jan. 11, 2023, the Consumer Financial Protection Bureau (“CFPB”) issued a proposed rule that would require nonbanks under its supervisory authority, subject to limited exceptions, to annually register information about...more

The Federal Trade Commission Proposes Ban on Employer-Worker Non-Compete Agreements

On Jan. 5, 2023, the Federal Trade Commission (FTC) issued a Notice of Proposed Rulemaking (Proposed Rule) seeking to categorically ban nearly all employer non-competition agreements nationwide. If passed in its draft form,...more

CFPB Invites Comments on Proposed Registry of Nonbank Financial Firms

Seeking to “enhance market monitoring and risk-based supervision efforts,” the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) has proposed a new, online registry of nonbank financial firms in order to track, what...more

CFPB Funding Structure Heads to Supreme Court in the Wake of Election

As the financial services industry continues to digest what is known so far about election results, a new twist for 2023 emerged this week when the Consumer Financial Protection Bureau (CFPB) put the question of the...more

Constitutionality of CFPB Funding Structure in the Crosshairs

Last week, the U.S. Court of Appeals for the Fifth Circuit ruled that the Consumer Financial Protection Bureau’s (CFPB) independent funding mechanism is unconstitutional. Under the Dodd-Frank Act, the CFPB is not funded...more

Congress Demands Answers About CFPB Authority for Recent Policymaking

This week, two House Republican Committee Ranking Members, Reps. Patrick McHenry (R-NC) from the House Financial Services Committee and James Comer (R-KY) from the House Oversight and Reform Committee, sent a letter to...more

Congress Pushes Back on Legal Authority for CFPB to Collaborate with State Attorneys General

As the Consumer Financial Protection Bureau (CFPB) continues to highlight coordination with state attorneys general, lawmakers and regulators, top congressional officials from the U.S. House Financial Services Committee...more

Using Complex Algorithms Is Not a Legal Defense for Discrimination

The Consumer Financial Protection Bureau recently warned companies that, under federal anti-discrimination laws, they still owe consumers an explanation of specific reasons for denying credit applications, even if they use...more

CFPB Blog Hints at Expanding FDCPA to Commercial Collections

The Consumer Financial Protection Bureau (CFPB) and Congress have both signaled an interest in expanding the scope of the Fair Debt Collection Practices Act (FDCPA) to cover commercial debt, a move that would likely subject...more

Proxy Problems—Solving for Discrimination in Algorithms

With regulators increasingly focusing on algorithmic discrimination, human intervention in predictive model programming and artificial intelligence (AI) will be more important than ever. Although the list of positive uses of...more

President Biden Mulling Executive Order on Cryptocurrencies: What to Watch For

The Biden administration is reportedly considering the issuance of an executive order that would create a governmentwide approach to the oversight and regulation of cryptocurrencies. Such an order would likely have...more

Actual Harm Required in Consumer Class Actions for FCRA

In its recent TransUnion LLC v. Ramirez decision, the U.S. Supreme Court clarified that consumer plaintiffs must be able to demonstrate concrete harm from a defendant’s statutory violation to have standing to seek monetary...more

Debt Collection Companies Beware: A Slew of Lawsuits Are Coming

Yesterday, the 11th Circuit Court of Appeals issued an opinion in Hunstein v. Preferred Collection and Management Services, Inc., -- F.3d --, 2021 WL 1556069 (Apr. 21, 2021), which almost immediately set off alarms in the...more

New FDCPA Rules: What’s Missing and What’s Still Coming

On Oct. 30, 2020, the Consumer Financial Protection Bureau (CFPB) issued a final rule clarifying prohibitions on harassment and abuse, false or misleading representations, and unfair practices by debt collectors when...more

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