As federal consumer protection enforcement has recently taken a sharp turn towards less regulation and enforcement, states continue efforts to fill the gap left by the federal pullback. ...more
Financial institutions that are regulated and supervised by the Office of the Comptroller of the Currency (OCC) should know that the OCC has recently updated its booklet on Unfair or Deceptive Acts or Practices (UDAP) and...more
In a consent order with a reverse mortgage servicer on June 18, 2024, the Consumer Financial Protection Bureau (CFPB) made the argument that failing to effectively service loans is abusive. The groundwork for this line of...more
The CFPB issued a report detailing the issues faced by consumers regarding credit card rewards programs and reminding credit card industry stakeholders that federal consumer protection laws—including the Consumer Financial...more
If you’ve been focused on only the high-level statements from the CFPB, you might already expect Rohit Chopra to fashion himself and the agency as “pro-consumer.” Consistent with that approach, the agency just signaled its...more
Can digital comparison-shopping operators or lead generators violate the Consumer Financial Protection Act (CFPA) by preferencing products or services based on financial benefit? According to today’s guidance issued by the...more
On April 3, 2023, the Consumer Financial Protection Bureau released a policy statement articulating a new framework for analyzing conduct that it considers “abusive” in violation of federal law. The CFPB until now has...more
In the CFPB’s second attempt to define “abusive” acts or practices, the first being guidance rescinded a year after it was given in 2020, the CFPB has issued a new policy statement in which it turns to statutory analysis and...more
On April 3, 2023, the CFPB published a new official statement of policy on the authority that Congress passed in the Consumer Financial Protection Act of 2010 (“CFPA”), codified at 12 U.S.C. § 5536(a)(1)(B), banning “abusive...more
The CFPB announced that it has entered into a consent order with Cash Express, LLC to settle charges that the company engaged in deceptive and abusive acts or practices in violation of the Consumer Financial Protection Act...more