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Consumer Protection Laws › Rulemaking Process › Consumer Financial Products

BCLP

Follow the Rules to Make the Rules: 8th Circuit Vacates “Click-to-Cancel” Rule

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The Eighth Circuit Court of Appeals has issued a per curiam opinion vacating the FTC’s Click-to-Cancel Rule based on the Federal Trade Commission (FTC)’s failure to comply with a procedural requirement in the FTC Act. This...more

Sheppard Mullin Richter & Hampton LLP

Eighth Circuit Vacates FTC’s “Click-to-Cancel” Negative Option Rule

Sheppard Mullin Richter & Hampton LLP on

On July 8, 2025, the U.S. Court of Appeals for the Eighth Circuit vacated the FTC’s “click-to-cancel” Negative Option Rule, holding that the FTC violated the FTC Act and the Administrative Procedure Act when it finalized the...more

Holland & Knight LLP

CFPB Publishes Additional Proposals to Rescind "Unnecessary" Rules and Regulations

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The CFPB continues on its path to rescind what it considers to be unnecessary regulatory guidance, with two additional proposals recently published. First, the agency published an interim final rule on May 16, 2025, to...more

Cooley LLP

CFPB Withdraws Guidance Documents in Shift from Nonbinding Policymaking

Cooley LLP on

After ordering the review of all existing guidance put forth by the Consumer Financial Protection Bureau (CFPB), acting CFPB Director Russell Vought announced the withdrawal of almost 70 guidance documents dating back to the...more

McGlinchey Stafford

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

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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

Katten Muchin Rosenman LLP

CFPB Proposes a New Rule Prohibiting Certain Contractual Terms for Consumer Financial Products

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On January 13, the Consumer Finance Protection Bureau (CFPB) published a new proposed rule attempting to ban certain contractual provisions in "take it or leave it" consumer contracts that purport to "waive substantive...more

Snell & Wilmer

FTC Click to Cancel Rule

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In 2023, the U.S. Federal Trade Commission (FTC) sought public comments on how to combat perceived unfair and deceptive trade practices, recurring subscription charges, and cancelation of such plans. Born out of these...more

Sheppard Mullin Richter & Hampton LLP

CFPB Announces Plans to Regulate Nonbank Personal Loan Providers

Sheppard Mullin Richter & Hampton LLP on

On January 8, the CFPB announced its intent to pursue rulemaking that would allow the agency to oversee nonbank personal loan lender. The announcement came in response to a petition filed in September 2022 by the Consumer...more

Sheppard Mullin Richter & Hampton LLP

California Expands Debt Collection Protections for Small Businesses and Consumers

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On September 24, California enacted a series of consumer protection laws, including three bills aimed specifically at restricting certain debt collection practices in connection with medical debt reporting, civil actions for...more

Bricker Graydon LLP

For now, lenders still on the hook under CFPB August 2019 payday rule

Bricker Graydon LLP on

Last year, the Consumer Financial Protection Bureau (CFPB) announced a new rule (the “payday rule”) that requires payday lenders to take additional steps to ensure borrowers are able to pay back their loans on time, launching...more

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