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 […]
Dodd-Frank Act
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 […]
Trends in D&O Insurance Coverage and Recommendations for Corporations and Financial Institutions
Directors and officers (D&O) insurance liability coverage terms continue to evolve in ways that can be important to directors and officers when lawsuits or investigations against them arise. In his 2022 speech “Reining in Repeat Offenders” at the Distinguished Lecture on Regulation at the University of Pennsylvania Law School, Director Rohit Chopra of the Consumer […]
CFPB Proposes Nonbank Registry to Focus on Compliance “Recidivism”
A&B ABstract: On December 12, 2022, the Consumer Financial Protection Bureau (CFPB) announced a proposed rule to require certain non-banks to register with the agency when they become subject to a public written order or judgment imposing obligations based on violations of certain consumer protection laws. The CFPB also proposes to maintain a public online […]
HELOCs On the Rise: Is Your Servicing CMS Ready?
A&B ABstract: The Consumer Financial Protection Bureau (“CFPB” or “Bureau”) has moved to clarify its regulatory authority at a time when the economic climate is ripe for a resurgence in HELOC lending. In an amicus brief filed by the CFPB on November 30, 2022 (the “Amicus Brief”), the Bureau acknowledged that its Mortgage Servicing Rules, […]