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Consumer Financial Protection Bureau (CFPB)

CFPB Issues Bulletin About Auto Repossession, Congressional Republicans Respond

March 24, 2022 By John Redding and Patrick Eagan-Van Meter

A&B Abstract: The Consumer Financial Protection Bureau (“CFPB” or the “Bureau”) recently released a Bulletin addressing the repossession of vehicles and alerting market participants to what it views as those market participants’ legal obligations under federal law governing unfair, deceptive, or abusive acts or practices (“UDAAP”).  That same day, the CFPB also published an inflammatory […]

Filed Under: Consumer Financial Protection Bureau (CFPB), Repossession, Unfair, Deceptive and Abusive Acts or Practices (UDAAP) Tagged With: #CFPB, UDAAP

CFPB’s SBREFA Outline on Automated Valuation Models Rekindles Debate over Disparate Impact Liability under the ECOA

February 26, 2022 By Brian Johnson and Melissa Malpass

Section 1473(q) of the Dodd-Frank Act (now codified at 12 U.S.C. § 3354(q)) amended the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (“FIRREA”) to instruct the CFPB, Fed, OCC, FDIC, NCUA, and FHFA (collectively, the “agencies”) to jointly develop regulations for quality control standards for automated valuation models (“AVMs”), defined as “any computerized […]

Filed Under: Consumer Financial Protection Bureau (CFPB), Dodd-Frank Act, Equal Credit Opportunity Act (ECOA), Supreme Court Decisions Tagged With: #CFPB, Fair Lending

Update regarding the BrightSpeed payment processor case

January 19, 2022 By Brian Johnson

On January 18, after approximately fourteen months of settlement negotiations, the CFPB announced that it secured a settlement agreement with BrightSpeed Solutions, Inc., a third-party payment processor that had ceased operations nearly three years ago. As we reported in greater detail in a prior post, the CFPB asserted jurisdiction to bring its complaint against BrightSpeed […]

Filed Under: Consumer Financial Protection Bureau (CFPB), Dodd-Frank Act Tagged With: #CFPB

Update Regarding the CFPB’s Buy Now, Pay Later Orders

January 7, 2022 By Brian Johnson

In a prior post, we reported that the language used in orders recently issued by the CFPB to leading Buy Now, Pay Later (“BNPL”) providers suggested that the CFPB intends to use the information it collects to build enforcement cases rather than monitor market developments. We also reported that if this is the case, it […]

Filed Under: Consumer Financial Protection Bureau (CFPB), Dodd-Frank Act, Fintech Tagged With: #BNPL, #CFPA, #CFPB

Is the CFPB using its market monitoring orders to build enforcement cases?

December 21, 2021 By Brian Johnson

As we previously noted, on October 21, the CFPB issued orders to six large technology firms seeking information about their payment product business plans (the “October 21 Orders”). According to the Bureau, the purpose of orders was to “shed light on the business practices of the largest technology companies in the world.” The CFPB’s use […]

Filed Under: Consumer Financial Protection Bureau (CFPB), Dodd-Frank Act Tagged With: #BigTech, #BNPL, #CFPB

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Recent Posts

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