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Constitutional Challenges Consumer Financial Products

Troutman Pepper Locke

New York Court of Appeals to Review FAPA’s Constitutionality and Retroactive Application

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As a follow up to our May post, FAPA in the Spotlight Again: Second Circuit Renews Call for NY Court of Appeals Review, the New York Court of Appeals has finally agreed to consider New York’s Foreclosure Abuse Prevention...more

Ballard Spahr LLP

What in the world does birthright citizenship have to do with consumer financial services?

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The short answer is that the outcome of the Supreme Court hearing (whose oral argument is scheduled for May 15 at 10 am) is of immense importance to all stakeholders in the consumer financial services industry. We will...more

Troutman Pepper Locke

Fifth Circuit Agrees to Dismiss CFPB’s UDAAP Examination Manual Appeal, Aligning with Bureau’s New Regulatory Priorities

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On May 1, the U.S. Court of Appeals for the Fifth Circuit dismissed the Consumer Financial Protection Bureau’s (CFPB or Bureau) appeal concerning the vacated amendments to its Unfair, Deceptive, or Abusive Acts and Practices...more

Ballard Spahr LLP

Disparate Impact Executive Order and HUD to Reconsider Disparate Impact Rule

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President Trump recently signed an Executive Order entitled “Restoring Equality of Opportunity and Meritocracy“ to eliminate the use of disparate impact liability. The U.S. Department of Housing and Urban Development (HUD)...more

Hudson Cook, LLP

The State Consumer Protection Beat: State AGs Kick Off 2025 with a String of Actions and Support for the CFPB

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The first two months of 2025 were filled with numerous consumer protection actions by state AGs against vehicle dealers and players in the mortgage space, among others. ...more

Troutman Pepper Locke

CFSA Attempts to Renew Small Dollar Lending Rule Litigation in Supreme Court Petition

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On March 7, the Community Financial Services Association of America (CFSA) and the Consumer Service Alliance of Texas filed a petition for a writ of certiorari with the U.S. Supreme Court seeking to overturn a decision by the...more

Troutman Pepper Locke

New Leadership and Dramatic Changes at the CFPB: Future of the Bureau Uncertain

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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

McGlinchey Stafford

Litigation Byte (December Edition)

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Delivered in digestible, insightful bites, McGlinchey’s Litigation Byte is a monthly roundup of financial services decisions and cases nationwide that impact your business....more

Ballard Spahr LLP

Appeals Court sets March 30, 2025 as effective date of CFPB payday lending rule

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A panel of the Fifth Circuit Court of Appeals has set March 30, 2025 as the effective date of the CFPB’s payday lending rule....more

Ballard Spahr LLP

Appeals court denies en banc hearing in CFSA’s challenge to CFPB’s payday rule

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The Fifth Circuit Court of Appeals has denied a request by the Community Financial Services Association of America (CFSA) to hold a rehearing en banc on the group’s challenge of the CFPB’s payday loan rule....more

Ballard Spahr LLP

Lender Fights Back Against CFPB Lawsuit, Arguing Unconstitutional Delegation of Power and Other Constitutional Violations

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On July 30, 2024, Heights Finance Holding Co. f/k/a Southern Management Corporation and a group of its wholly-owned, state-licensed subsidiaries (collectively, “Southern”) filed a motion for judgment on the pleadings (the...more

Ballard Spahr LLP

Another target of CFPB enforcement action argues that lawsuit filed on August 23, 2023 must be dismissed because the CFPB lacked...

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We have recently blogged about two other actions in which this issue has been raised (one being a declaratory judgment action filed against the CFPB on July 23, 2024 in the E.D. Tex. and the other being an enforcement action...more

Ballard Spahr LLP

Populus files motion to dismiss CFPB enforcement action based on fact that CFPB has been unlawfully funded by Fed when it had no...

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We have previously blogged about an enforcement action brought on July 12, 2022 by the CFPB against Populus Financial Group, Inc., d/b/a ACE Cash Express, Inc. in Federal District Court for the Northern District of Texas...more

Ballard Spahr LLP

Rent-to-Own Company Sues CFPB Over Authority to Regulate RTO Transactions

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Part 1 – The CFPB has no authority to investigate or sue Acima because, under Dodd-Frank and the appropriations Clause of the Constitution, it may only be funded out of combined earnings of the Federal Reserve System and...more

Ballard Spahr LLP

Update on CFPB payday lending rule: “it ain’t over ‘till it’s over”

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On June 14, the CFPB announced that its payday lending rule would become effective on  March 30, 2025.  However, the CFPB ignored the possibility of further litigation in CFSA v. CFPB, the case challenging the payday lending...more

Troutman Pepper Locke

Fifth Circuit Rules CFPB Credit Card Late Fee Rule Case Stays in Texas

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On June 18, the Fifth Circuit Court of Appeals granted the plaintiffs’ petition for a writ of mandamus, effectively halting the transfer of the lawsuit challenging the Consumer Financial Protection Bureau’s (CFPB or Bureau)...more

Ballard Spahr LLP

Fifth Circuit (again) rejects transfer of credit card late fee case to D.C.

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On June 19, 2024, the Fifth Circuit dissolved the district court’s order transferring the case challenging the CFPB’s credit card late fee rule. In granting the writ of mandamus filed by the plaintiff trade associations...more

Ballard Spahr LLP

CFPB announces March 30, 2025 compliance date for payday lending rule

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In a blog post published at the end of last week, the CFPB announced that its payday lending rule (Rule) would go into effect on March 30, 2025.  Because the Rule’s ability to pay requirements were rescinded, the only...more

Ballard Spahr LLP

A reply to Professor Sovern’s arguments as to why the Fed, notwithstanding its losses, can still lawfully fund the CFPB

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Although neither the CFPB, the Federal Reserve Board, nor the Treasury has responded to Professor Emeritus Hal Scott’s op-ed on May 20 in the Wall Street Journal, my interview with Professor Scott on our Consumer Finance...more

Ballard Spahr LLP

Consumer Finance Monitor Podcast Episode: Did the Supreme Court Hand the CFPB a Pyrrhic Victory?

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Special guest Professor Hal Scott of Harvard Law School joins us today as we delve into the thought-provoking question of whether the Supreme Court’s recent decision in the landmark case of CFSA v. CFPB really hands the CFPB...more

Akerman LLP

Explainer Things: Season 2 Episode 3

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It has been a busy time for us at Explainer Things. Awards season is over, but the fintech regulatory drama is in midseason form. The star of this episode is of course the Supreme Court’s decision on the future of the CFPB....more

Ballard Spahr LLP

Transfer Redux: Once again, CFPB Late Fee litigation transferred from Texas to DC, transfer challenged in Fifth Circuit

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In a replay of earlier events, in response to an emergency petition for writ of mandamus and administrative stay of transfer filed by the plaintiffs in the lawsuit challenging the legality of the CFPB’s credit card late fee...more

Troutman Pepper Locke

Texas District Court Orders Transfer of the Credit Card Late Fee Rule Lawsuit to D.C. … Again: Fifth Circuit Promptly Issues Stay

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On Tuesday, the lawsuit challenging the Consumer Financial Protection Bureau’s (CFPB or Bureau) credit card late fee rule (Final Rule) was ordered to be transferred from the U.S. District Court for the Northern District of...more

Mayer Brown

The Consequences of the US Supreme Court’s Decision Upholding the CFPB’s Funding Structure

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On May 16, 2024, the US Supreme Court upheld the constitutionality of the Consumer Financial Protection Bureau’s (“CFPB”) funding structure in a decision that will have significant ramifications on both the CFPB’s rulemaking...more

Ballard Spahr LLP

Was it a pyrrhic victory for the CFPB in the Supreme Court in CFSA v. CFPB?

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On May 16, Justice Thomas issued the majority opinion in which the Supreme Court held, by a 7-2 vote, that the CFPB’s funding mechanism comported with the Appropriations Clause of the Constitution which states, in relevant...more

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