News & Analysis as of

Consumer Financial Products Disclosure Requirements Enforcement Actions

A&O Shearman

FCA statement on motor finance review next steps

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The UK Financial Conduct Authority (FCA) has published a statement informing firms, consumers and stakeholders of next steps in its review of the past use of motor finance discretionary commission arrangements. The Court...more

Sheppard Mullin Richter & Hampton LLP

California DFPI Reaches Settlement with Lender Over Crypto-Backed Loans

On December 23, 2024, the California Department of Financial Protection and Innovation (DFPI) announced a consent order with a lender to resolve its investigation into the company’s crypto-backed lending program, which the...more

McGlinchey Stafford

FTC’s CARS Rule Vacated — What Finance Companies Need to Know

McGlinchey Stafford on

In a procedural decision, the U.S. Court of Appeals for the Fifth Circuit vacated the CARS Rule (officially, the Combatting Auto Retail Scams Trade Regulation Rule, sometimes known as the Vehicle Shopping Rule) which was...more

Orrick, Herrington & Sutcliffe LLP

FDIC fines bank $650K for alleged unfair and deceptive acts

On January 31, the FDIC publicly announced its order for a bank in Sandy, Utah, to pay a civil money penalty of $650,000 due to allegations of deceptive acts and unfair practices. ...more

Ballard Spahr LLP

CFPB orders remittance transfer provider to pay almost $2.5 million for alleged illegal activities

Ballard Spahr LLP on

On January 30, 2025, the CFPB ordered Wise, an international remittance company, to pay almost $2.5 million in connection with allegations of illegal activities, including advertising inaccurate fees and failing to properly...more

Sheppard Mullin Richter & Hampton LLP

CFPB Orders Remittance Company to Pay $2.5 Million for Deceptive Practices and Inaccurate Disclosures

On January 30, 2025, the CFPB issued an order against a remittance company for misleading consumers about fees and failing to provide accurate disclosures, harming consumers who relied on the company’s representations when...more

Kelley Drye & Warren LLP

Washington AG's Bark Has Some Bite

On January 17, Washington Attorney General Nick Brown announced that his office had reached a resolution in its nearly two-year lawsuit against Puppyland, a local pet store that sells and provides financing for (you guessed...more

Sheppard Mullin Richter & Hampton LLP

CFPB Issues Warning on Risks of Home Equity Contracts, Takes Legal Action to Ensure Compliance with TILA

On January 17, 2024, the Consumer Financial Protection Bureau (CFPB) issued a report, consumer advisory, and filed an amicus brief addressing the risks associated with home equity contracts (HECs)—financial products often...more

Latham & Watkins LLP

Unpacking the FTC’s New Negative Option Rule, Its Legal Challenges, and Future Uncertainty

Latham & Watkins LLP on

The rule impacts both B2B and B2C subscription autorenewals and other negative option programs; however, significant legal challenges could impact the rule’s implementation....more

McDermott Will & Schulte

New Requirements for Illinois Dental Practices Using Third-Party Financing

Third-party financing services are frequently used by patients to finance out-of-pocket dental expenses. Effective January 1, 2025, dental practices in Illinois are prohibited from facilitating or assisting with patient...more

Sheppard Mullin Richter & Hampton LLP

Consumer Fees Find Themselves in the Crosshairs: The CFPB Seeks Public Input on Alleged “Junk Fees” in the Consumer Financial...

The Consumer Financial Protection Bureau (“CFPB”) has continued to ratchet up its regulatory scrutiny over the consumer financial services market. On January 26, 2022, the CFPB published an initiative seeking public input on...more

Ballard Spahr LLP

CFPB enters into consent order with small-dollar lender to settle alleged TILA and UDAAP violations arising from finance charge...

Ballard Spahr LLP on

The CFPB announced last week that it has entered into a consent order with Triton Management Group, Inc., a small-dollar lender, to settle the CFPB’s allegations that Triton had violated the Truth in Lending Act and the...more

K&L Gates LLP

Seller Beware: Lessons Learned from 2015 Deceptive Advertising Enforcement in the Consumer Finance Space

K&L Gates LLP on

Federal regulators took a close look at advertisements for consumer financial products and services in 2015, bringing over 25 enforcement actions totaling over $975 million in penalties and consumer redress. In the majority...more

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