News & Analysis as of

UDAAP Disclosure Requirements

Kelley Drye & Warren LLP

HelloFresh to Pay $7.5 Million to Settle Automatic Renewal Suit

Last month, HelloFresh agreed to settle an investigation by the California Automatic Renewal Task Force (“CART”) made up of several California counties and cities. CART’s lawsuit, filed contemporaneously with its agreed...more

Orrick, Herrington & Sutcliffe LLP

Massachusetts state court allows consumer protection suit over home equity investment product to proceed

On August 21, a Massachusetts superior court denied a motion to dismiss filed by a financial technology company offering a home equity investment (HEI) product. The financial technology company asserted that the HEI is an...more

Cozen O'Connor

FTC Sues LA Fitness to Cancel Unfair Membership Cancellation Practices

Cozen O'Connor on

The FTC has sued Fitness International, LLC and Fitness & Sports Clubs, LLC—the operators of “LA Fitness”—alleging that the gyms have made it extremely difficult for consumers to cancel memberships and recurring charges in...more

Cozen O'Connor

State AGs Are Stepping Up — Is Your Bank Ready for Multistate Scrutiny?

Cozen O'Connor on

The CFPB has scaled back some enforcement priorities, and the states have noticed. Certain states – including California, New York, Texas, and Connecticut – are particularly active, pursuing UDAP violations, privacy issues,...more

Mayer Brown

Texas Commercial Financing Disclosure and Registration Law Threatens Sales-Based Financing Industry

Mayer Brown on

Texas has enacted a law that has the potential to place substantial impediments on sales-based financing providers, including merchant cash advance companies, seeking to operate in Texas. The new Texas law prohibits...more

Fox Rothschild LLP

FTC: Be Precise and Accurate With Your Advertising or Beware

Fox Rothschild LLP on

The Federal Trade Commission is taking a hard look at marketing and advertising statements, making sure they are precise and accurate. Here are some key takeaways from recent enforcements:...more

Sheppard Mullin Richter & Hampton LLP

Massachusetts AG Issues New Regulations Targeting Junk Fees 

On March 3, Massachusetts Attorney General Andrea Joy Campbell announced new regulations, issued under the Massachusetts Consumer Protection Act, aimed at curbing “junk fees” by requiring businesses to disclose total prices...more

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

Nelson Mullins Riley & Scarborough LLP

Adding Fuel to the Fire: Is the FDIC Inadvertently Encouraging Lawsuits Against Banks Over NSF Fees?

The Federal Deposit Insurance Corporation (“FDIC”) on August 18, 2022 issued updated Supervisory Guidance on banks assessing multiple re-presentment fees against customers’ accounts. This follows the March 2022 FDIC Consumer...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

Sheppard Mullin Richter & Hampton LLP

Proposed California Commercial UDAAP and Annual Reporting Regs to be promulgated under California Consumer Financial Protection...

Two weeks after the DFPI set a Dec. 9 effective date for its long-threatened commercial financing disclosure requirement (we discussed these regulations in a previous bog, here), the DFPI issued proposed commercial UDAAP and...more

Morrison & Foerster LLP

The Other Shoe Drops: The California DFPI Issues Proposed UDAAP Regulations for Providers of Commercial Financing to Small...

Two weeks after the issuance of its commercial financing disclosure regulations, the California Department of Financial Protection and Innovation issued a Notice of Proposed Action with draft regulations that would (1) expand...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

Sheppard Mullin Richter & Hampton LLP

Apple Privacy Nutrition Labels Effective Starting Next Month

Apple has launched, in connection with other privacy changes in iOS 14, a requirement for privacy “nutrition labels.” The labels are required for new and existing apps, and are in addition to the existing requirement of...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

Ballard Spahr LLP

Fed issues consent order for bank’s alleged deceptive practices involving balance transfer credit cards

Ballard Spahr LLP on

The Federal Reserve Board announced that it had issued a Consent Order against Mid America Bank and Trust Company (Bank) for alleged deceptive marketing practices in violation of section 5 of the FTC Act related to balance...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

K&L Gates LLP

A Careful Balancing Act: Second Circuit Requires Debt Collectors to Disclose When a Consumer’s Current Balance May Increase Due to...

K&L Gates LLP on

In Avila v. Riexinger & Associates, LLC, No. 15-1584, --- F.3d ---, 2016 WL 1104776 (2d Cir. Mar. 22, 2016), the Second Circuit Court of Appeals construed the scope of Section 1692e of the Fair Debt Collection Practices Act...more

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