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CFPB Focuses on Junk Fees, Credit Reporting, and COVID-19 Relief Funds in Latest Supervisory Highlights

On November 16, the Consumer Financial Protection Bureau (CFPB) released a new Supervisory Highlights report, focusing on the auto servicing industry, consumer reporting, mortgage servicing, and COVID-19 relief funds. The...more

CFPB Files Cert Petition Requesting Expedited Review of Fifth Circuit Decision Finding Funding Structure Unconstitutional

As discussed here, on October 19, a three-judge panel of the Fifth Circuit Court of Appeals held that the Consumer Financial Protection Bureau’s (CFPB) funding mechanism violates the appropriations clause because the CFPB...more

Texas Federal Court Finds Biden Student Loan Forgiveness Program Unconstitutional

The Biden administration’s student loan forgiveness program is on hold indefinitely after a Texas federal court issued its decision, finding the program to be unconstitutional. In Brown v. U.S. Department of Education, the...more

AG's Office Sues Automobile Dealership for Pricing Discrimination - The Consumer Finance Podcast [Audio]

Please join Consumer Financial Services Partner Chris Willis and his colleagues Stefanie Jackman and Chris Carlson as they discuss the recent action by the Massachusetts attorney general (AG) involving automobile dealer...more

CFPB Warns CRAs and Furnishers of FCRA Liability for Failing to Conduct Proper Investigations

On November 10, the Consumer Financial Protection Bureau (CFPB) published a circular, stating that both consumer reporting agencies (CRAs) and furnishers may be held liable under the Fair Credit Reporting Act (FCRA) for...more

Texas Federal Court Issues Stay Pending Fifth Circuit Mandate

On October 31, a Texas federal court ordered a stay in a Consumer Financial Protection Bureau (CFPB) enforcement action, pending the issuance of the Fifth Circuit mandate in Community Financial Services Association of America...more

Supreme Court Hears Arguments on Challenges to Agency Enforcement Proceedings

Do district courts have jurisdiction to hear constitutional challenges to federal agencies, or must plaintiffs first raise such challenges in administrative proceedings before the agency? On November 7, the U.S. Supreme Court...more

CFPB Seeks Further Input on Shifting P2P Fraud Liability to Banks

In an October 27 letter, the American Bankers Association (ABA) expressed concern regarding a proposal currently being considered by the Consumer Financial Protection Bureau (CFPB) that would shift liability from consumers to...more

Permanent Version of DC’s Protecting Consumers From Unjust Debt Collection Practices Amendment Act Takes Effect January 1, 2023

As we previously discussed here, in March 2022, the D.C. Council of the District of Columbia Committee of the Whole met in a full hearing, in part to hear amendments introduced to B24-0357, known as the Protecting Consumers...more

CFPB Examines Potential Impact of Student Loan Payment Reinstatement

On November 2, the Consumer Financial Protection Bureau (CFPB) released a blog post, exploring the potential impact of student loan payment reinstatement. The CFPB found that student loan borrowers are increasingly likely to...more

CFPB Calls Fifth Circuit Decision “Neither Controlling Nor Correct”

Unsurprisingly, defendants in two separate enforcements actions filed by the Consumer Financial Protection Agency (CFPB) have cited the Fifth Circuit’s recent decision in Community Financial Services Association of America,...more

CFPB Issues Advisory Opinion to Consumer Reporting Agencies to Remove “Facially False Data” to Maintain FCRA Compliance

Pursuant to its authority under Section 1022(b)(1) of the Dodd-Frank Act, the Consumer Financial Protection Bureau (CFPB) issued an advisory opinion to consumer reporting agencies (CRAs), highlighting their obligation to...more

CFPB Signals Interest in Higher Education Lending Practices

The Consumer Financial Protection Bureau (CFPB) recently issued a report, focused on the current student loan servicing market that laid out the results of several supervisory efforts related to student lending. Higher...more

NY Department of Financial Services Reaches Settlement With Bank Over Alleged Fair Lending Violations Involving Auto Dealer...

On October 6, the New York State Department of Financial Services (NYDFS) announced a consent order with Rhinebeck Bank (Rhinebeck) to resolve allegations that, in violation of New York Executive Law Section 296-a, the bank...more

Fifth Circuit Finds CFPB Funding Structure Unconstitutional

In a major decision released October 19, a three-judge panel of the Fifth Circuit Court of Appeals found the funding mechanism for the Consumer Financial Protection Bureau (CFPB or Bureau) to be unconstitutional....more

FTC and CFPB Provide Guidance on Buy Now, Pay Later Products After State AGs Urge CFPB for Oversight

In March 2022, state attorneys general provided comments to the Consumer Financial Protection Bureau (CFPB) concerning the CFPB’s inquiry into companies that offer consumers the opportunity to divide the cost of their...more

Banking Groups Refute Senator Warren’s Report on P2P Fraud

Banking groups are taking issue with a report by Senator Elizabeth Warren (D-MA) regarding the prevalence of fraud on Zelle, the popular peer-to-peer (P2P) payment service. In an October 3 joint statement, the Consumer...more

Proposed Legislation Would Allow Furnishing Utility and Phone Bills to Credit Reporting Agencies

On September 26, Representative French Hill (R-AR) introduced new legislation, H.R. 8985, also known as the Credit Access and Inclusion Act of 2022, to amend the Fair Credit Reporting Act and allow payment information for...more

Chambers of Commerce and Banking Groups File Suit Against CFPB for Overstepping Its Authority With UDAAP Exam Manual Amendment

On September 28, the U.S. Chamber of Commerce (Chamber), together with the Longview Chamber of Commerce, American Bankers Association, Consumer Bankers Association, Independent Bankers Association of Texas, Texas Association...more

Keeping Up With the Bureau Episode 4: Hot Topics in Collections: Fees, Reg F Landscape, and What’s Next - The Consumer Finance... [Audio]

Please join Consumer Financial Services Partner Stefanie Jackman and her guests and colleagues James Trefil and Jonathan Floyd in the fourth and final episode of a special four-part series on recent developments at the...more

CFPB Examines Potential Impact of Rising Car Prices on Consumer Credit

On September 19, the Consumer Financial Protection Bureau (CFPB) released a blog post, exploring the potential relationship between rising car prices and changes in auto loan performance. The CFPB found that the rate of...more

Tenth Circuit Adopts “Reasonable Consumer” Standard to Determine Materiality Under FDCPA

The standard courts should use to determine whether an alleged Fair Debt Collection Practices Act (FDCPA) violation is material remains unsettled. According to a recent Tenth Circuit decision, however, the standard should be...more

Eleventh Circuit En Banc Panel Reverses Controversial Hunstein Decision

In a much anticipated decision released September 8, an en banc panel of the Eleventh Circuit Court of Appeals reversed the district court’s decision that a debt collector’s outsourcing of its letter process to a third-party...more

California Publishes Notice of Proposed Rulemaking Regulating Student Loan Servicing

On August 30, the California Department of Financial Protection and Innovation (CA DFPI) published a notice of rulemaking action, proposing amendments to the Student Loan Servicing Act....more

Keeping Up With the Bureau Episode 1: Overview of CFPB and State AG Initiatives/Expansion - The Consumer Finance Podcast [Audio]

Please join Consumer Financial Services Partner Chris Willis and his guests and colleagues Ashley Taylor and Stefanie Jackman in the first episode of a special four-part series about recent developments with the Consumer...more

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