Consumer Finance Monitor Podcast Episode: State Fair Access and Debanking Laws Bring Country’s Political and Cultural Divisions to the Fore
Unraveling the Legal Threads: A Deep Dive Into Earned Wage Access - Payments Pros: The Payments Law Podcast
Troutman Pepper Attorneys Update Fair Lending Handbook for the American Association of Bank Directors - The Consumer Finance Podcast
Consumer Finance Podcast Monitor Episode: The Consumer Financial Protection Bureau’s Final Section 1071 Rule on Small Business Data Collection: What You Need to Know, Part II, Guest David Skanderson
CFPB's Section 1071 Final Rule (Part 3): Potential Problem Areas – The Consumer Finance Podcast
Illinois Federal Court Dismisses CFPB's First Redlining Case, Holding ECOA Doesn't Extend to Prospective Applicants - The Consumer Finance Podcast
FTC Consent Order With Auto Dealer and Proposed Rule - The Consumer Finance Podcast
On July 10, the Massachusetts attorney general announced a $2.5 million settlement with a Delaware-based student loan company to resolve allegations that the company’s lending practices, including the use of artificial...more
Recent Consumer Financial Protection Bureau ("CFPB") guidance reiterates that creditors must provide consumers with accurate and individualized explanations for adverse actions—a task made more difficult by the complexity of...more
On September 19, 2023, the Consumer Financial Protection Bureau (CFPB) issued new guidance outlining lenders’ obligations under the Equal Credit Opportunity Act (ECOA) and Regulation B when using artificial intelligence (AI)...more
In May 2022, the CFPB issued Circular 2022-3 addressing Equal Credit Opportunity Act (ECOA) adverse action notice requirements in connection with credit decisions based on algorithms. The CFPB is now revisiting the issue in...more
When using artificial intelligence (AI) or complex credit models, can lenders rely on the checklist of reasons provided in Regulation B sample forms for adverse action notices? According to today’s guidance issued by the...more
As OpenAI’s release of ChatGPT in late 2022 and expected release of GPT-4 in 2023 continues to garner widespread attention, there is renewed focus on both opportunities and risks presented by the use of artificial...more
In this article, we share a timeline of our monthly "bites" for 2022 applicable to small-dollar lending. So, what happened in 2022?...more
Compliance lawyers last summer were predicting that the Consumer Financial Protection Bureau (CFPB) would announce a robust regulatory agenda under the Biden administration, but we had not yet seen many details that allowed...more
As previously discussed, financial services regulators are increasingly focused on how businesses use artificial intelligence (AI) and machine learning (ML) in underwriting and pricing consumer finance products. Although...more
Anti-discrimination law applies to companies with black-box credit models using complex algorithms, according to a circular issued by the Consumer Financial Protection Bureau (CFPB) on May 26, 2022. According to the CFPB, the...more
The federal government continues to take significant interest in organizations using artificial intelligence and algorithmic decision-making systems, as evidenced by three recent developments out of Washington, D.C. ...more
The Consumer Financial Protection Bureau (CFPB) has been contemplating data, algorithms, and machine learning for years. In 2017, as part of a field hearing on alternative data, the CFPB issued a request for information in...more
The Consumer Financial Protection Bureau (“CFPB”) released a regulatory Circular providing guidance regarding the use of “complex algorithms” to assess whether a consumer should be extended credit. Often referred to as “black...more
Andrew Smith, Director of the FTC Bureau of Consumer Protection, has written a blog post, “Using Artificial Intelligence and Algorithms,” in which the FTC “offer[s] important lessons about how companies can manage the...more