What Happened? Earlier this week, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) released a blog post touting its 2023 successes in safeguarding “household financial stability” through the levying of fines and filing of lawsuits. The Bureau highlighted seven enforcement cases: Protecting Servicemembers from Illegal High-Interest Loans and False Advertising: In February 2023, the CFPB ordered an […]
Consumer Loan
OCC Issues Guidance on “Buy Now, Pay Later” Lending
A&B Abstract: On December 6, 2023, the Office of the Comptroller of the Currency (OCC) issued a bulletin aimed at providing guidance to national banks and federal savings associations (“Financial Institutions”) involved in “buy now, pay later” (BNPL) lending. The advisory emphasizes the need for these Financial Institutions to carefully manage risks associated with BNPL, […]
Oh Snap! CFPB Sues Fintech Company under CFPA and TILA
A&B Abstract: On July 19, 2023, the Consumer Financial Protection Bureau (CFPB) sued a Utah-based fintech company and several of its affiliates (the Company) for allegedly deceiving consumers and obscuring the terms of its financing agreements in violation of the Consumer Financial Protection Act (CFPA), the Truth in Lending Act (TILA), and other federal regulations. […]
CFPB Issues Special Edition of Supervisory Highlights Focusing on Junk Fees
A&B ABstract: In the 29nd edition of its Supervisory Highlights, the Consumer Financial Protection Bureau (“CFPB”) focused on the impact of so-called “junk” fees in the mortgage servicing, auto servicing, and student loan servicing industries, among others. CFPB Issues New Edition of Supervisory Highlights: On March 8, the CFPB published a special edition of its […]
CFPB Issues Proposed Rule to Establish Public Registry of Supervised Nonbank Form Contract Provisions that Waive or Limit Consumers’ Legal Protections
A&B ABstract: On January 11, 2023, the Consumer Financial Protection Bureau (the “CFPB” or “Bureau”) announced a proposed rule to establish a public registry and require nonbanks supervised by the agency to register their use of certain terms and conditions contained in “take it or leave it” form contracts for consumer financial products or services […]