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Consumer Financial Protection Bureau (CFPB) Advisory Opinions Consumer Financial Products

Troutman Pepper Locke

CFPB Will Not Reissue Medical Debt Advisory Opinion

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On July 14, the Consumer Financial Protection Bureau (CFPB or Bureau) filed a status report announcing its decision not to reissue its Medical Debt Collection Advisory Opinion, which had been issued in 2024 to “remind debt...more

Sheppard Mullin Richter & Hampton LLP

CFPB Withdraws Dozens of Guidance Documents as Part of Deregulatory Push

On May 12, the CFPB formally withdrew nearly 70 guidance materials—including policy statements, advisory opinions, circulars, and interpretive rules—through a Federal Register notice issued by Acting Director Russell...more

Ballard Spahr LLP

CFPB revokes EWA advisory opinion

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The CFPB rescinded an advisory opinion that had described how one particular type of “earned wage” product did not involve the offering or extension of “credit” as that term is defined in the Truth in Lending Act and...more

Orrick, Herrington & Sutcliffe LLP

CFPB rescinds previous opinion regarding how one EWA product was not a “loan”

On January 15, the CFPB issued an advisory opinion rescinding its 2020 advisory opinion on earned wage access (EWA) products. As previously covered by InfoBytes, the CFPB’s 2020 advisory opinion stated that a certain EWA...more

Troutman Pepper Locke

CFPB Rescinds 2020 Advisory Opinion on Earned Wage Access Products

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As part of a flurry of last minute regulatory activity by the Biden administration’s Consumer Financial Protection Bureau (CFPB or Bureau), on January 15, the CFPB published an advisory opinion in the Federal Register...more

Ballard Spahr LLP

ACA International files suit challenging CFPB medical debt advisory opinion

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ACA International, the association representing the accounts receivable industry, has filed suit against the CFPB, alleging that the bureau’s advisory opinion on medical debt was overtly political, issued in violation of the...more

Troutman Pepper Locke

CFPB Voluntarily Extends Effective Date of Advisory Opinion on Medical Debt

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Earlier this month, we discussed the lawsuit filed by ACA International, LLC and Collection Bureau Services, Inc. in the U.S. District Court for the District of Columbia against the Consumer Financial Protection Bureau (CFPB...more

Troutman Pepper Locke

CFPB Intensifies Scrutiny on Medical Debt Collection Practices

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On October 1, the Consumer Financial Protection Bureau (CFPB or Bureau) issued an advisory opinion aimed at debt collectors and emphasizing their obligations under the Fair Debt Collection Practices Act (FDCPA) and Regulation...more

Ballard Spahr LLP

Consumer Finance Monitor Podcast Episode: Navigating the Consumer Financial Protection Bureau’s Proposed Personal Financial Data...

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In October 2023, the CFPB issued a groundbreaking proposal on personal financial data. This episode, which repurposes a webinar, begins with a review of the background of the rulemaking. We then discuss key provisions of the...more

Ballard Spahr LLP

CFPB comments on California proposal to supervise providers of earned wage access products

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The Consumer Financial Protection Bureau has sent a letter to the California Department of Financial Protection and Innovation (DFPI) commenting on the DFPI’s proposal that would require providers of “income-based advances”...more

Troutman Pepper Locke

CFPB Advises Large Banks on Compliance with CFPA § 1034(c)

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On October 11, the Consumer Financial Protection Bureau (CFPB or Bureau) issued an advisory opinion regarding § 1034(c) of the Consumer Financial Protection Act (CFPA), which requires large banks and credit unions to comply...more

Ballard Spahr LLP

CFPB issues advisory opinion on fees charged by large banks and credit unions to respond to information requests and releases data...

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As we have previously reported on this blog and discussed on our Consumer Finance Monitor Podcast, last year, the CFPB embarked on a campaign orchestrated by the Biden Administration to eliminate “junk fees.” ...more

Sheppard Mullin Richter & Hampton LLP

CFPB’s RESPA Advisory Addresses Digital Mortgage Comparison-Shopping Platforms, Lead Generation

On February 7, the CFPB issued an Advisory Opinion to address the applicability of RESPA section 8 to operators of certain digital technology platforms that enable consumers to comparison shop for mortgages and other real...more

BCLP

CFPB guidance on pay-to-pay fees impacts consumer loan agreements

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Consumer debt collectors may not be permitted to charge consumers “convenience fees” for card payments, which the Consumer Financial Protection Board (the “CFPB”) calls “pay-to-pay” fees, unless the underlying loan agreement...more

Wiley Rein LLP

Wiley Consumer Protection Download (July 12, 2022)

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Regulatory Announcements- CFPB Issues Advisory Opinion on FCRA Permissible Purposes for Providing Consumer Reports. On July 7, the CFPB issued an Advisory Opinion on the Fair Credit Reporting Act (FCRA) that outlines...more

Sheppard Mullin Richter & Hampton LLP

CFPB Affirms that ECOA Protects Consumers After Receiving Credit

On May 9, the CFPB released an advisory opinion affirming that ECOA and its implementing rule, Regulation B, protect not only those persons actively seeking credit, but also those who have sought and received credit. The...more

Goodwin

CFPB Affirms Regulation Z Does Not Apply To Non-Recourse Earned Wage Access

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Recently, the Consumer Financial Protection Bureau (CFPB) issued an order accepting into the CFPB’s compliance assistance sandbox an earned wage access (EWA) program where participating employees are not obligated to repay...more

Ballard Spahr LLP

CFPB issues compliance assistance sandbox approval for earned wage access product

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The CFPB has issued an approval order through its Compliance Assistance Sandbox Policy (CAS Policy) to Payactiv in connection with its earned wage access (EWA) program....more

Skadden, Arps, Slate, Meagher & Flom LLP

Consumer Financial Protection Bureau Launches Advisory Opinion Process

On June 18, 2020, the Consumer Financial Protection Bureau (CFPB or Bureau) announced the pilot of a new Advisory Opinion process, offering a potentially useful tool for those seeking guidance on compliance issues. ...more

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