News & Analysis as of

Enforcement Actions Truth in Lending Act (TILA) Financial Services Industry

Ballard Spahr LLP

CFPB won’t prioritize BNPL enforcement

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The CFPB will not make enforcement of its Buy Now, Pay Later rule a priority, according to a recent statement....more

Troutman Pepper Locke

CFPB Rescinds Dozens of Regulatory Guidance Documents in Major Regulatory Shift

Troutman Pepper Locke on

The Consumer Financial Protection Bureau (CFPB or Bureau) announced the withdrawal of 67 regulatory guidance documents, including interpretive rules, policy statements, and advisory opinions that have been issued since the...more

Brownstein Hyatt Farber Schreck

CFPB Drops Indirect Lending Case

On April 22, the Consumer Financial Protection Bureau (CFPB) requested the U.S. District Court for the Southern District of New York to remove the bureau as a plaintiff in CFPB v. Credit Acceptance Corporation, a case that...more

Ballard Spahr LLP

Home equity contracts: The CFPB weighs in

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If there was any doubt about how the Consumer Financial Protection Bureau (“CFPB”) (under current leadership) feels about what it calls “home equity contracts” (also known as shared appreciation agreements, shared equity...more

Husch Blackwell LLP

CFPB Reboots Policy Statements for No-Action Letters and Compliance Assistance Sandbox Approvals Days Before Administration Change

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On January 10, 2025, the Consumer Financial Protection Bureau (CFPB) revived its policy statements on No-Action Letters (NALs) and Compliance Assistance Sandbox (CAS) Approvals. These unexpected changes come just days before...more

Hudson Cook, LLP

CFPB Settles with Online Student Lender for Alleged Deceptive Marketing Practices and Miscalculated and Undisclosed Annual...

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On October 17, 2024, the CFPB filed a lawsuit against the Companies claiming violations of the CFPA, TILA, and Regulation Z. The CFPB alleged that the Companies engaged in deceptive acts and practices by representing that it...more

Goodwin

CFPB Sues Online Lender of Student Loans for Alleged Violations of Federal Lending Laws

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On October 17, 2024, the Consumer Finance Protection Bureau (CFPB) announced that it had filed an action in the U.S. District Court for the Southern District of New York against an online lender of student loans, its...more

Goodwin

CFPB Enters into Consent Orders with Tech Company and Bank Over Credit Card Allegations

Goodwin on

On October 23, 2024, the CFPB announced that it had entered into separate consent orders with a large tech company and a bank over a joint credit card venture. The CFPB alleges that the credit card, which combined the tech...more

Ballard Spahr LLP

CFPB sues Horizon Card Services and CEO, saying they cheated low-income people through membership scheme

Ballard Spahr LLP on

The CFPB earlier this month filed suit against Horizon Card Services and its CEO and sole shareholder Robert Kane for allegedly tricking subprime consumers into signing up for a high-fee credit card that only allowed them to...more

Hudson Cook, LLP

CFPB Sues Credit Card Issuer and its Owner and CEO for Alleged Deceptive Marketing and Improper Fees

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On September 13, 2024, the CFPB filed a lawsuit against the company and its owner and CEO, alleging deceptive and abusive acts and practices in violation of the CFPA and violations of TILA and its implementing regulation....more

Hudson Cook, LLP

CFPB Takes Action Against Mortgage Servicer for Alleged Order Violations and Servicing Errors

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On August 21, 2024, the CFPB issued a Consent Order against the Company citing alleged failure to provide accurate information about loss mitigation options and improper handling of loan modifications. The Consent Order...more

Goodwin

CFPB Enters Into Consent Order With Mortgage Servicer Resolving Allegations of Improper Foreclosure Practices

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On August 21, 2024, the Consumer Financial Protection Bureau (CFPB)​ announced​ that it entered into a consent order with a​ Florida-based mortgage servicer, resolving allegations related to the mortgage servicer’s...more

Ballard Spahr LLP

CFPB files and prosecutes yet another enforcement lawsuit using funds obtained in violation of the CFPB’s enabling statute...

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The Introduction to the Complaint which was filed by the CFPB on May 17, 2024 against Solo Funding, Inc. in the United States District Court for the Central District of California – Western Division Los Angeles (Judge R. Gary...more

Ballard Spahr LLP

Another target of CFPB enforcement action argues that lawsuit filed on August 23, 2023 must be dismissed because the CFPB lacked...

Ballard Spahr LLP on

We have recently blogged about two other actions in which this issue has been raised (one being a declaratory judgment action filed against the CFPB on July 23, 2024 in the E.D. Tex. and the other being an enforcement action...more

Goodwin

CFPB Files Proposed Judgment in Bank Suit Regarding the Opening of Unauthorized Accounts

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​On July 9, 2024, the Consumer Financial Protection Bureau (CFPB) announced that it filed a proposed stipulated final judgment and ​order in its suit against a national bank accused of allegedly opening unauthorized accounts...more

Venable LLP

CFPB to Launch Registry of Nonbank Enforcement Actions

Venable LLP on

In a move that's sure to make nonbank financial institutions even more uncomfortable, the Consumer Financial Protection Bureau (CFPB) has decided to shine a brighter light on those that have been alleged to violate consumer...more

Ballard Spahr LLP

CFPB Takes Action Against BloomTech, Inc. for ISAs that Violate TILA, UDAAP, and the FTC’s Holder Rule

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On April 17th, the CFPB issued a consent order to a for-profit training school alleging numerous violations of law related to its use if income share agreements (“ISAs”). According to the Bureau, BloomTech, Inc. (“BloomTech”)...more

Goodwin

2023 Year in Review: Fintech

Goodwin on

Welcome to the Fintech chapter of our annual report Consumer Financial Services 2023 Year in Review. Looking Ahead to 2024 - The CFPB is expected to finalize rulemaking authorizing supervision of payment application...more

Goodwin

CFPB and Several States Order Vocational Education Company to Pay Fines, Cancel Loans, and Cease Operations After Allegedly...

Goodwin on

On November 20, 2023, the Consumer Financial Protection Bureau (CFPB) announced that, in conjunction with 11 states, it entered into a stipulated final judgment with a Delaware-based vocational education company that...more

Nutter McClennen & Fish LLP

Nutter Bank Report: November 2023

Headlines 1. Recent Bank Failures The FDIC has issued a final rule that will impose special assessments to recover the loss to the Deposit Insurance Fund (Fund) arising from the systemic risk determination announced on March...more

Goodwin

Bureau Sues Snap Finance for Its Financing Options to Asset Limited Consumers

Goodwin on

On July 19, 2023, the Consumer Financial Protection Bureau (“CFPB”) sued Snap Finance LLC, Snap R TO LLC, Snap Second Look LLC, Snap U.S. Holdings LLC, and Snap Finance Holdings LLC (collectively, the Snap Defendants or...more

Hudson Cook, LLP

CFPB Bites of the Month - July 2023 - Freedom, Independence, and Celebration From the CFPB

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In this month's article, we share some of our top "bites" for the prior month covered during the July 2023 webinar. Bite 10: Public Inquiry Launched into Credit Card and Loan Products for Healthcare Costs - On July 7,...more

Ballard Spahr LLP

CFPB and 11 states file lawsuit against companies engaged in origination and collection of income share agreements

Ballard Spahr LLP on

The Consumer Financial Protection Bureau, the California Department of Financial Protection and Innovation (CA DFPI), and ten state Attorneys General have filed a lawsuit against Prehired, LLC (Prehired) and two related...more

Orrick, Herrington & Sutcliffe LLP

OCC releases enforcement actions (UPDATE)

On May 18, the OCC released a list of recent enforcement actions taken against national banks, federal savings associations, and individuals currently and formerly affiliated with such entities. Among the enforcement actions...more

Hudson Cook, LLP

CFPB Fines National Bank $9 Million for Improper Handling of Credit Card Billing Error Notices and Claims of Unauthorized Use

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The CFPB settled a lawsuit originally filed in January 2020 against a large national bank, claiming it violated the Truth in Lending Act and its implementing Regulation Z, as well as the Consumer Financial Protection Act, by...more

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