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Morgan Lewis

CFPB Invites Comment on Larger Participant Thresholds

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The Consumer Financial Protection Bureau has issued advance notices of proposed rulemaking seeking public comment on whether to revise the thresholds that define “larger participants” in key consumer financial industries....more

Ballard Spahr LLP

CFPB Seeks Comments On Raising ‘Larger Participant’ Thresholds

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On August 8, 2025, the Consumer Financial Protection Bureau (“CFPB”) issued four advance notices of proposed rulemaking (“ANPR”) inviting comments on whether it should substantially reduce the number of nonbank companies the...more

Troutman Pepper Locke

The Current State of the Holder Rule: Friend or Foe? — Moving the Metal: The Auto Finance Podcast

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In this episode of Moving the Metal: The Auto Finance Podcast, Brooke Conkle and Chris Capurso from Troutman Pepper Locke's Consumer Financial Services Practice Group examine the current status of the Federal Trade...more

Troutman Pepper Locke

2024 Consumer Financial Services Year in Review and A Look Ahead

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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

Troutman Pepper Locke

CFPB Releases Report Highlighting Auto Lending Challenges for Servicemembers

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On January 29, the Consumer Financial Protection Bureau (CFPB or Bureau) released a report analyzing the auto lending market’s impact on servicemembers. ...more

BCLP

Our Top 5 Banking Litigation Cases From 2024 - Looking Back to Look Forward

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2024 was a busy year for the Courts in England and Wales when it came to banking and wider financial services disputes. We were spoilt for choice when selecting our top 5 cases and, inevitably, have left out some significant...more

Troutman Pepper Locke

CFPB Releases Report on Auto Repossessions

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As discussed here, in February 2023, the Consumer Financial Protection Bureau (CFPB or Bureau) launched the auto finance data pilot and issued nine market monitoring orders to three banks, three finance companies, and three...more

Troutman Pepper Locke

Auto Finance Under the Microscope: Unpacking Landmark FTC and AG Settlements — Moving the Metal: The Auto Finance Podcast

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In this episode, Brooke Conkle and Chris Capurso from Troutman Pepper Locke’s Consumer Financial Services Practice Group are joined by Chris Carlson, a partner in the Regulatory Investigations Strategy and Enforcement...more

Orrick, Herrington & Sutcliffe LLP

NY Fed: Consumers report higher credit rejection rates, expect more rejection

Recently, the New York Fed’s Center for Microeconomic Data released its latest Survey of Consumer Expectations Credit Access Survey, which highlights trends in consumer credit experiences and expectations. The survey,...more

Troutman Pepper Locke

2024 Privacy Trends and Their Impact on Auto Finance – Moving the Metal: The Auto Finance Podcast

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In this episode, Brooke Conkle and Chris Capurso, attorneys in the firm's Consumer Financial Services Practice Group, are joined by Kim Phan, a partner in the firm's Privacy and Cyber Practice Group. They delve into the...more

Troutman Pepper Locke

Lemon Law Shakeup: Rodriguez vs. FCA US Has Unexpected Result – Moving The Metal Podcast

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In this episode, Brooke Conkle and Chris Capurso, attorneys in the firm’s Consumer Financial Services practice, are joined by Partner Ethan Ostroff to discuss the recent Supreme Court of California decision in Rodriguez vs....more

Troutman Pepper Locke

CFPB's Supervisory Highlights on Auto-Finance and Auto-Servicing — Moving the Metal: The Auto Finance Podcast

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In this special joint episode of The Consumer Finance Podcast and Moving the Metal, Chris Willis teams up with Brooke Conkle and Chris Capurso, hosts of the Moving the Metal podcast, to discuss the CFPB’s recent supervisory...more

Troutman Pepper Locke

CFPB’s Supervisory Highlights on Auto-Finance and Auto-Servicing — The Consumer Finance Podcast

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In this special joint episode of The Consumer Finance Podcast and Moving the Metal, Chris Willis teams up with Brooke Conkle and Chris Capurso, hosts of the Moving the Metal podcast, to discuss the CFPB’s recent supervisory...more

Troutman Pepper Locke

Breaking Granite: Understanding New Amendments to the New Hampshire Retail Installment Sales Act — Moving the Metal: The Auto...

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In this episode of Moving the Metal, Chris and Brooke break down recent amendments to the New Hampshire Retail Installment Sales Act. On August 2, New Hampshire Governor Chris Sununu signed HB 1243 into law, bringing...more

Troutman Pepper Locke

Dissecting Oral Arguments in NADA's Challenge to the CARS Rule — Moving the Metal: The Auto Finance Podcast

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In this podcast episode, Brooke Conkle and Chris Capurso are joined by esteemed senior practitioner Alan Wingfield to discuss the National Automobile Dealer Association’s (NADA) challenge to the Federal Trade Commission’s...more

Wiley Rein LLP

Wiley Consumer Protection Download (October 15, 2024)

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Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more

McGlinchey Stafford

CFPB Issues Auto Finance Supervisory Highlights Sharing Marketing, Servicing, and Add-on Findings

McGlinchey Stafford on

A new “Auto Finance Special Edition” of the Consumer Financial Protection Bureau’s (CFPB or Bureau) Supervisory Highlights was released on October 7, 2024, and it is important for those overseeing compliance in their auto...more

Cooley LLP

CFPB Reveals Auto Financing and Servicing Concerns in Latest Report

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On October 7, 2024, the Consumer Financial Protection Bureau (CFPB) released its most recent Supervisory Highlights report, which largely focuses on auto finance issues identified in examinations completed by the CFPB between...more

Ballard Spahr LLP

CFPB focuses on auto finance practices in latest Supervisory Highlights

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On October 7, the CFPB released the Fall edition of its Supervisory Highlights, “Special Edition Auto Finance,” focusing on the auto finance market. The report highlights various supervisory observations and enforcement...more

Troutman Pepper Locke

CFPB’s Fall Edition of Supervisory Highlights Focuses on Auto-Finance Market

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On October 7, the Consumer Financial Protection Bureau (CFPB or Bureau) published the Fall edition of its Supervisory Highlights, focusing on examinations of the auto-finance market completed between November 1, 2023, and...more

Hudson Cook, LLP

CFPB Issues Consent Order Related to Bank's Duplicative Force-Placed Insurance Policies

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On July 9, 2024, the Consumer Financial Protection Bureau issued a consent order against a nationally chartered bank that, among other things, includes a number of allegations related to the bank's policies regarding...more

Ballard Spahr LLP

Consumer groups show support of CFPB’s Auto Finance Data Pilot and urge the Bureau to expand its data collection

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In February 2023, the Consumer Financial Protection Bureau (“CFPB” or the “Bureau”) announced an auto finance data pilot, where it ordered nine large auto lenders to provide information about their auto lending portfolios....more

Ballard Spahr LLP

Appeals Court Says Terms and Conditions Contained in Unsigned Auto Rental ‘Terms and Conditions’ are Part of the Consumer Contract

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Unsigned Terms and Conditions found in a preprinted car rental jacket are part of the contract between the parties under Florida, Arizona and Colorado law because they were properly incorporated by reference into the signed...more

Troutman Pepper Locke

Loans, Retail Installment Contracts, and Refinancing Programs — Moving the Metal: The Auto Finance Podcast

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In this episode, Brooke Conkle and Chris Capurso delve into the topic of refinancing and its impacts on the auto finance industry. They are joined by special guest Jason Cover, who provides insights and education on retail...more

Troutman Pepper Locke

The CFPB’s Report on Negative Equity in Auto Lending - Moving the Metal: The Auto Finance Podcast

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In this episode of Moving the Metal, Troutman Pepper attorneys Brooke Conkle and Chris Capurso discuss the Consumer Financial Protection Bureau’s (CFPB) new report on negative equity in auto lending. This report, the first of...more

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