News & Analysis as of

Disclosure Requirements UDAAP Consumer Financial Protection Bureau (CFPB)

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

Hudson Cook, LLP

Speaking Multiple Languages Is Great for Business, but Do You Know When You Are Required to Provide Translated Documents?

Hudson Cook, LLP on

The United States is a big melting pot of cultures, ethnicities, and languages. This diversity is great for business, but if you are advertising that your business speaks "Spanish" or that your business can assist customers...more

BCLP

Deceptive and Unfair - Multiple NSF Fees on Representments of the Same Transaction

BCLP on

In guidance issued recently, the Federal Deposit Insurance Corporation (“FDIC”) advised that charging multiple non-sufficient funds (“NSF”) fees constitute “violations of law” when customer disclosures do not fully and...more

Ballard Spahr LLP

FTC proposes new rule imposing prohibitions and disclosure requirements on auto-dealers in car-buying process

Ballard Spahr LLP on

The Federal Trade Commission (FTC) recently proposed a rule that would impose a number of new substantive and disclosure requirements on auto-dealers in the car-buying process. The FTC described the proposed Rule as one...more

Nutter McClennen & Fish LLP

Nutter Bank Report: March 2022

CFPB Announces Intention to Expand Enforcement Against Unfair Discrimination - The CFPB has published an updated examination manual for evaluating unfair, deceptive, and abusive acts and practices (“UDAAPs”), which explains...more

Goodwin

CFPB Launches New Initiative Focused on Rural Communities

Goodwin on

In This Issue. The Consumer Financial Protection Bureau (CFPB) announced a new initiative focused on financial issues faced by rural communities and also updated its examination procedures to cover unfair discrimination; the...more

Goodwin

SEC Adopts Broad Exempt Offering Reforms

Goodwin on

In the News. The Securities and Exchange Commission (SEC) adopted broad exempt offering reforms; the Department of Labor (DOL) finalized a rule, with significant revisions from the original proposal, on ESG investments; the...more

Ballard Spahr LLP

CFPB Enters Into Consent Order With Small-Dollar Lender To Settle Alleged TILA And UDAAP Violations

Ballard Spahr LLP on

The CFPB announced that it has entered into a consent order with Main Street Personal Finance, Inc. and two subsidiaries (Main Street), each a small-dollar lender, to settle the CFPB’s allegations that Main Street (1)...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

Bradley Arant Boult Cummings LLP

A Deeper Dive: The CFPB Short-Term Small- Dollar Lending Rule

Introduction - By now you’ve likely heard that the Consumer Financial Protection Bureau (CFPB) has released a final small-dollar lending rule. The hallmark of the rule is the requirement That lenders make a reasonable...more

Ballard Spahr LLP

CFPB issues guidance on pay-by-phone fees

Ballard Spahr LLP on

The CFPB has issued a new compliance bulletin (2017-11) to provide guidance on pay-by-phone fees.  The guidance includes examples of conduct relating to pay-by-phone practices identified by the CFPB in its supervision and...more

Smith Debnam Narron Drake Saintsing & Myers,...

CFPB Consent Orders with Consumer Reporting Agencies Focus on Marketing Practices not Credit Reporting

Marketing practices remain at the forefront of CFPB activity as evidenced by two recent consent orders entered into with TransUnion and Equifax. The consent orders combine to require the CRAs to pay more than $17.6 million...more

Ballard Spahr LLP

CFPB finalizes no-action policy for innovative financial products

Ballard Spahr LLP on

The CFPB has issued a final policy statement on issuing “no-action” letters (NAL) for innovative financial products or services. The CFPB’s statement that the final policy was released on its website on February 18, 2016...more

Morgan Lewis

CFPB Issues List of Consumer Protection Concerns for New Faster Payment Systems

Morgan Lewis on

The Consumer Protection Principles continue the CFPB’s expansive approach. Stating that it wants to ensure that “any new payment systems are secure, transparent, accessible, and affordable to consumers” and have “robust...more

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