A&B Abstract: On September 29, 2022, the Consumer Financial Protection Bureau (“CFPB”), sued MoneyLion Technologies Inc. and 37 of its subsidiaries (“MoneyLion”) in New York federal court for violations of the Military Lending Act (the “MLA”) and Consumer Financial Protection Act (“CFPA”). The Allegations The CFPB alleges that MoneyLion offered installment loans that consumers could […]
Consumer Financial Protection Bureau (CFPB)
CFPB and DOJ Announce Redlining Settlement Against Non-Bank Mortgage Lender
A&B Abstract: On July 27, 2022, the Consumer Financial Protection Bureau (“CFPB”) and the US Department of Justice (“DOJ”) entered into a settlement with Trident Mortgage Company (“Trident”), resolving allegations under the Equal Credit Opportunity Act (“ECOA”) and the Fair Housing Act that the non-bank mortgage lender intentionally discriminated against majority-minority neighborhoods in the greater […]
Joint Trade Associations Reject the CFPB’s “Discrimination-Unfairness” Theory
In a June 28 letter to Director Chopra and accompanying White Paper and press release, the ABA, CBA, ICBA, and the U.S. Chamber of Commerce have called on the Consumer Financial Protection Bureau (CFPB or Bureau) to rescind recent revisions made to its UDAAP examination manual that had effectuated the CFPB’s controversial theory that alleged […]
Did the CFPB Have Authority to Issue its RFI Regarding Employer-Driven Debt?
A&B Abstract The CFPB’s statutory authority to issue a recent request for information (RFI) regarding employer-driven debt is in doubt, which may affect the utility of any comments submitted in response to its request. Background On June 9, the CFPB issued an RFI Regarding Employer-Driven Debt. The RFI seeks comment on several areas of inquiry […]
Second Juneteenth Holiday Raises Tricky Compliance Issues
A&B Abstract The second observance of the Juneteenth National Independence Day (Juneteenth) holiday is Monday, June 20, 2022. President Biden signed legislation making Juneteenth National Independence Day a federal national holiday last year. Because the fixed date holiday falls on a Sunday, the second observance of Juneteenth raises tricky compliance issues for the timing of […]