Yesterday, the New York City Department of Consumer and Worker Protection (NYC DCWP) announced another delay in the effective date of its amended debt collection rules. This marks the second postponement. As discussed here,...more
On July 14, the Office of the Comptroller of the Currency (OCC) issued Bulletin 2025-16, announcing the removal of references to disparate impact liability from the “Fair Lending” booklet of the Comptroller’s Handbook and...more
7/16/2025
/ Anti-Discrimination Policies ,
Banks ,
Borrowers ,
Consumer Financial Products ,
Deregulation ,
Discriminatory Lending Practices ,
Disparate Impact ,
Equal Access to Credit ,
Executive Orders ,
Fair Lending ,
Financial Regulatory Reform ,
Financial Services Industry ,
Handbooks ,
Lenders ,
OCC ,
Regulatory Authority ,
Regulatory Requirements ,
Trump Administration
Today, the Consumer Financial Protection Bureau (CFPB or Bureau) published a policy statement in the Federal Register outlining its approach to addressing criminally liable regulatory offenses. This publication comes in...more
6/27/2025
/ Consumer Financial Protection Bureau (CFPB) ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Deregulation ,
Enforcement Actions ,
Enforcement Priorities ,
Executive Orders ,
Financial Crimes ,
Financial Regulatory Reform ,
Penalties ,
Regulatory Agenda ,
Regulatory Reform ,
Reporting Requirements ,
Trump Administration ,
White Collar Crimes
On May 22, Illinois House Bill 3352 passed the Illinois legislature and now awaits Governor JB Pritzker’s signature. This bill amends the Illinois Collection Agency Act to provide an individual a way to avoid liability for a...more
6/12/2025
/ Coercion ,
Consumer Privacy Rights ,
Damages ,
Debt ,
Debt Collection ,
Financial Regulatory Reform ,
Financial Services Industry ,
Fraud ,
Government Agencies ,
Illinois ,
New Legislation ,
Penalties ,
State and Local Government ,
Statutory Violations
Last week, the Consumer Financial Protection Bureau (CFPB or Bureau) submitted several regulatory proposals to the Office of Management and Budget (OMB) for review. Among the rules under consideration are those related to...more
6/10/2025
/ Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Dodd-Frank ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Mortgage Lenders ,
Mortgage Loan Originators ,
Mortgage Servicers ,
Mortgages ,
OMB ,
Proposed Rules ,
Regulation X ,
Regulation Z ,
Regulatory Agenda ,
Regulatory Oversight ,
Regulatory Reform
On May 15, the Consumer Financial Protection Bureau (CFPB or Bureau) officially rescinded its May 2022 interpretive rule concerning the scope of state enforcement authority under § 1042 of the Consumer Financial Protection...more
5/22/2025
/ Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Enforcement Actions ,
Financial Regulatory Reform ,
Regulatory Authority ,
Regulatory Oversight ,
Regulatory Reform ,
State and Local Government ,
State Attorneys General ,
Statutory Interpretation ,
UDAAP
On May 14, the Consumer Financial Protection Bureau (CFPB or Bureau) published a proposed rule to rescind amendments to its Procedures for Supervisory Designation Proceedings, originally adopted in 2022 and 2024. This...more
5/19/2025
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Financial Institutions ,
Financial Regulatory Reform ,
Non-Bank Lenders ,
Proposed Amendments ,
Proposed Rules ,
Public Comment ,
Regulatory Agenda ,
Regulatory Oversight ,
Rescission ,
Risk Management ,
Supervision
Yesterday, the Consumer Financial Protection Bureau (CFPB or Bureau) filed its decision to withdraw the proposed rule titled “Protecting Americans from Harmful Data Broker Practices (Regulation V)” in the Federal Register....more
5/15/2025
/ Consumer Financial Protection Bureau (CFPB) ,
Consumer Privacy Rights ,
Data Brokers ,
Deregulation ,
Fair Credit Reporting Act (FCRA) ,
Financial Regulatory Reform ,
Financial Services Industry ,
Proposed Regulation ,
Proposed Rules ,
Regulation V ,
Regulatory Reform ,
Regulatory Requirements ,
Rescission ,
Statutory Authority ,
Trump Administration
Yesterday, the Consumer Financial Protection Bureau (CFPB or Bureau) released a proposed rule to rescind its previous regulation requiring nonbank entities to report certain agency and court orders to a Bureau registry....more
5/14/2025
/ Comment Period ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Final Rules ,
Financial Regulatory Reform ,
Financial Services Industry ,
Non-Bank Lenders ,
Proposed Rules ,
Regulatory Requirements ,
Reporting Requirements ,
Rescission ,
Rulemaking Process
On May 9, the U.S. Senate Committee on Banking, Housing, and Urban Affairs announced that President Trump signed into law Chairman Tim Scott’s (R-SC) Congressional Review Act (CRA) resolution, effectively overturning the...more
5/13/2025
/ American Bankers Association ,
Banks ,
Biden Administration ,
Congressional Review Act ,
Consumer Financial Protection Bureau (CFPB) ,
Deregulation ,
Financial Regulatory Reform ,
Financial Services Industry ,
Overdraft Fees ,
Popular ,
Regulatory Reform ,
Trump Administration
The Consumer Financial Protection Bureau (CFPB or Bureau) announced the withdrawal of 67 regulatory guidance documents, including interpretive rules, policy statements, and advisory opinions that have been issued since the...more
5/12/2025
/ Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Deregulation ,
ECOA ,
EFTA ,
Enforcement Actions ,
Fair Credit Reporting Act (FCRA) ,
FDCPA ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Guidance Documents ,
Military Lending Act ,
Policy Statement ,
Popular ,
Regulatory Reform ,
Regulatory Requirements ,
Rulemaking Process ,
Statutory Interpretation ,
Trump Administration ,
Truth in Lending Act (TILA)
This week, the Consumer Financial Protection Bureau (CFPB or Bureau) released a memo to staff outlining its new supervision and enforcement priorities for 2025....more
4/18/2025
/ Banking Sector ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Discriminatory Lending Practices ,
Enforcement Actions ,
Fair Credit Reporting Act (FCRA) ,
Fair Lending ,
FDCPA ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Mortgages ,
Regulatory Reform ,
Regulatory Requirements ,
Supervisory Guidance ,
Trump Administration
The Consumer Financial Protection Bureau (CFPB or Bureau) agreed to vacate its controversial credit card late fee rule in a joint motion for entry of consent judgment filed in Chamber of Commerce of the United States of...more
4/16/2025
/ Administrative Procedure Act ,
CARD Act ,
Consent ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Cards ,
Final Rules ,
Financial Regulatory Reform ,
Financial Services Industry ,
Judicial Authority ,
Late Fees ,
Penalties ,
Regulatory Requirements ,
Statutory Violations ,
Vacated
On April 9, the House of Representatives passed two Congressional Review Act (CRA) joint resolutions aimed at nullifying certain Consumer Financial Protection Bureau (CFPB) rules finalized in the final days of the...more
4/14/2025
/ Congressional Review Act ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Final Rules ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Nullification ,
Overdraft Fees ,
Regulatory Reform ,
Regulatory Requirements
In this final episode of our Year in Review series, Chris Willis is joined by colleagues David Anthony, Stefanie Jackman, and Jonathan Floyd to discuss the year in review and look ahead for debt collection. They provide...more
We are pleased to share our annual review of regulatory and legal developments in the consumer financial services industry. With active federal and state legislatures, consumer financial services providers faced a challenging...more
2/17/2025
/ Automotive Loans ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Enforcement Actions ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinTech ,
Regulatory Agenda ,
Regulatory Requirements ,
TCPA ,
UDAAP ,
Uniform Commercial Code (UCC)
On February 11, President Donald Trump nominated Jonathan McKernan to be the new Director of the Consumer Financial Protection Bureau (CFPB or Bureau). If confirmed by the Senate, McKernan will replace Acting CFPB Director...more
2/13/2025
/ Administrative Appointments ,
Consumer Financial Protection Bureau (CFPB) ,
Enforcement ,
FDIC ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Nominations ,
Regulatory Agencies ,
Regulatory Agenda ,
Regulatory Reform ,
Trump Administration
In a dramatic series of events, the Consumer Financial Protection Bureau (CFPB or Bureau) has undergone leadership changes, signaling a significant shift in its regulatory approach. These changes began with the firing of...more
2/11/2025
/ Administrative Appointments ,
Constitutional Challenges ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Dodd-Frank ,
Financial Regulatory Reform ,
Financial Services Industry ,
Regulatory Agencies ,
Regulatory Agenda ,
Regulatory Reform ,
Trump Administration
On February 4, Senators Bernie Sanders (I-Vt.) and Josh Hawley (R-Mo.) introduced bipartisan legislation aimed at immediately capping credit card interest rates at 10% for a period of five years. This initiative follows a...more
In a significant and highly anticipated move, President Donald Trump has fired Rohit Chopra, the Director of the Consumer Financial Protection Bureau (CFPB or Bureau). Rohit Chopra, who had been serving as the Director of the...more
Join host Kim Phan and special guests David Anthony, Stefanie Jackman, and Mark Furletti as they delve into the significant Fair Credit Reporting Act (FCRA) developments of 2024 and provide insights on what to expect in 2025....more
Earlier this month, the Consumer Financial Protection Bureau (CFPB or Bureau) issued new policy statements regarding its Compliance Assistance Sandbox (CAS) and No-Action Letters (NAL) programs. ...more
1/24/2025
/ Competition ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Enforcement Actions ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Innovation ,
No-Action Letters ,
Regulatory Agenda ,
Regulatory Oversight ,
Sandbox ,
Supervision ,
Transparency
As the Consumer Financial Protection Bureau (CFPB or Bureau) anticipates a shift in its leadership with the incoming administration of President Trump, the Bureau has released a report titled “Strengthening State-Level...more
1/16/2025
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Privacy Rights ,
Data Privacy ,
Enforcement Actions ,
Federal v State Law Application ,
Financial Regulatory Reform ,
Financial Services Industry ,
Hidden Fees ,
New Legislation ,
Regulatory Agenda ,
Trump Administration
The Consumer Financial Protection Bureau (CFPB or Bureau) proposed a new rule aimed at banning certain contractual provisions in agreements for consumer financial products or services. The CFPB’s proposal targets certain...more
1/15/2025
/ Arbitration Agreements ,
Comment Period ,
Consumer Financial Contracts ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Contract Terms ,
Federal Trade Commission (FTC) ,
Financial Regulatory Reform ,
Proposed Rules ,
Public Comment ,
Regulatory Agenda ,
Small Business ,
Unfair or Deceptive Trade Practices
The Consumer Financial Protection Bureau (CFPB or Bureau) finalized a rule aimed at removing an estimated $49 billion in medical bills from the consumer reports of approximately 15 million Americans. This rule amends...more
1/9/2025
/ Consumer Financial Protection Bureau (CFPB) ,
Consumer Reporting Agencies ,
Consumer Reports ,
Credit Reports ,
Fair Credit Reporting Act (FCRA) ,
Final Rules ,
Financial Regulatory Reform ,
Healthcare ,
Medical Debt ,
Regulation V ,
Trade Associations