News & Analysis as of

Consumer Financial Protection Act (CFPA) Abusive Acts

WilmerHale

New York Legislature Passes FAIR Business Practices Act

WilmerHale on

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

Foley & Lardner LLP

Office of the Comptroller of the Currency Updates “Unfair or Deceptive Acts or Practices and Unfair, Deceptive, or Abusive Acts or...

Foley & Lardner LLP on

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

Bradley Arant Boult Cummings LLP

CFPB: Ineffective Loan Servicing Is an Abusive Act or Practice

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

Cozen O'Connor

CFPB Reports “Doom Loops” and Other Harmful Practices in Credit Card Rewards Programs

Cozen O'Connor on

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

Venable LLP

Why the CFPB’s Preferencing and Steering Practices Circular Should Scare Lead Generators and Consumer Financial Services Providers

Venable LLP on

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

Troutman Pepper Locke

CFPB Warns Digital Comparison-Shopping Operators and Lead Generators That Steering Consumers Could Violate the CFPA, But Fails to...

Troutman Pepper Locke on

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

Cooley LLP

CFPB Issues Policy Statement on CFPA’s Prohibition on ‘Abusive’ Conduct

Cooley LLP on

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

Ballard Spahr LLP

CFPB releases policy statement defining abusive acts or practices

Ballard Spahr LLP on

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

Seyfarth Shaw LLP

CFPB Publishes New Policy Statement on Abusive Acts and Practices

Seyfarth Shaw LLP on

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

Ballard Spahr LLP

CFPB announces consent order with small-dollar lender

Ballard Spahr LLP on

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

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