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As has been well-documented, the Consumer Financial Protection Bureau (CFPB or Bureau) is navigating a period of significant uncertainty. Just last week, the U.S. Court of Appeals for the District of Columbia vacated a...more
On May 1, the U.S. Court of Appeals for the Fifth Circuit dismissed the Consumer Financial Protection Bureau’s (CFPB or Bureau) appeal concerning the vacated amendments to its Unfair, Deceptive, or Abusive Acts and Practices...more
To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week....more
We are pleased to share our annual review of regulatory and legal developments in the consumer financial services industry. With active federal and state legislatures, consumer financial services providers faced a challenging...more
The U.S. Supreme Court’s ruling last week in CFSA v. CFPB that the CFPB’s funding mechanism does not violate the Appropriations Clause of the U.S. Constitution removes what many observers consider to be the last remaining...more
It’s clear that President Joe Biden’s approach toward consumer protection and financial services enforcement will differ from that of his predecessor. In addition to general housekeeping matters, such as replacing and hiring...more
California’s governor is expected to sign into law soon a bill creating a state consumer financial protection agency, the Department of Financial Protection and Innovation (DFPI), which some have called California’s...more
The New York Department of Financial Services (NYDFS) is New York’s primary regulator of financial institutions, consumer protection, and financial activity. With jurisdiction over more than 1,500 financial institutions, the...more
A group of 24 Democratic state attorneys general and the D.C. attorney general have submitted a comment letter to the CFPB setting forth their opposition to the CFPB’s proposal to delay the compliance date for the...more
The BCFP has issued proposed revisions to its 2016 final policy on issuing “no-action” letters (NAL), together with a proposal to create a new “BCFP Product Sandbox.” Comments must be received on or before February 11, 2019....more
Addressing the Mortgage Bankers Association (MBA) 2018 Annual Convention in Washington, D.C., on October 15, 2018, CFPB Acting Director Mick Mulvaney advised that regulation by enforcement is dead, and that he does not care...more
Addressing the Mortgage Bankers Association (MBA) 2018 Annual Convention in Washington, DC on October 15, 2018, BCFP Acting Director Mick Mulvaney advised that regulation by enforcement is dead, and that he does not care much...more