On October 7, the Consumer Financial Protection Bureau (CFPB or Bureau) published the Fall edition of its Supervisory Highlights, focusing on examinations of the auto-finance market completed between November 1, 2023, and...more
10/9/2024
/ Add-ons ,
Automotive Loans ,
Banks ,
Borrowers ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Reports ,
Financial Services Industry ,
Loans ,
Supervisory Highlights ,
Truth in Lending Act (TILA)
As discussed here, last week the U.S. Supreme Court issued its long-awaited decision in Community Financial Services Association of America, Limited (CFSA) v. Consumer Financial Protection Bureau (CFPB or Bureau) holding that...more
5/20/2024
/ Banks ,
Constitutional Challenges ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Financial Protection Bureau v Community Financial Services Association of America Ltd ,
Dodd-Frank ,
Federal Funding ,
Final Rules ,
Financial Institutions ,
Financial Services Industry ,
SCOTUS ,
Section 1071
On March 29, the Federal Deposit Insurance Corporation (FDIC) announced two more consent orders containing provisions relating to banks’ third-party risk management programs with respect to banking as a service (BaaS)...more
We are pleased to share our annual review of regulatory and legal developments in the consumer financial services industry. With active federal and state legislatures, consumer financial services providers faced a challenging...more
2/1/2024
/ Automotive Loans ,
Banks ,
Class Action ,
Consumer Bankruptcy ,
Consumer Financial Products ,
Debt Collection ,
Digital Assets ,
Fair Lending ,
Financial Services Industry ,
FinTech ,
Mortgages ,
Student Loans ,
Tribal Loans ,
Uniform Commercial Code (UCC)
In this episode of The Consumer Finance Podcast, Troutman Pepper Partners Chris Willis and Matthew Orso discuss lessons learned from bank internal investigations. They explore the trigger points that give rise to these...more
On August 28, the U.S. Department of Justice (DOJ) announced its eighth redlining settlement under its Combatting Redlining Initiative. The settlement between the DOJ and the American Bank of Oklahoma, which originated from a...more
8/31/2023
/ Banks ,
Consent Order ,
Department of Justice (DOJ) ,
Discriminatory Lending Practices ,
ECOA ,
Enforcement Actions ,
Fair Housing Act (FHA) ,
FDIC ,
Mortgage Lenders ,
Mortgages ,
Race Discrimination ,
Redlining ,
Settlement
On August 10, two credit union trade associations — Credit Union National Association (CUNA) and Cornerstone Credit Union League — and Rally Credit Union (collectively, Proposed Intervenors) filed an Unopposed Emergency...more
8/15/2023
/ American Bankers Association ,
Banks ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Financial Protection Bureau v Community Financial Services Association of America Ltd ,
Consumer Protection Act ,
Data Collection ,
Dodd-Frank ,
Final Rules ,
Financial Institutions ,
Financial Services Industry ,
Regulatory Agencies ,
Reporting Requirements ,
SCOTUS ,
Section 1071 ,
Stays
On August 8, bankers associations from all 50 states sent a joint letter to the Consumer Financial Protection Bureau (CFPB or Bureau) urging it to stay enforcement and implementation of the small business data collection and...more
8/11/2023
/ American Bankers Association ,
Banks ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Financial Protection Bureau v Community Financial Services Association of America Ltd ,
Consumer Protection Act ,
Dodd-Frank ,
Final Rules ,
Financial Institutions ,
Financial Services Industry ,
SCOTUS ,
Section 1071 ,
Stays
Please join Troutman Pepper Partners Chris Willis and Stefanie Jackman, along with special guest Prodigal Banking Strategy Leader Scott Hamilton for a discussion about how voice AI and machine learning contribute to more...more
On June 29, the Federal Financial Institutions Examination Council (FFIEC) announced the availability of data on 2022 mortgage lending transactions reported under the Home Mortgage Disclosure Act (HMDA) by U.S. financial...more
On December 10, 2023, New York General Business Law § 520-e requiring a grace period for the use of credit card rewards points will go into effect. Specifically, the legislation provides that if any credit card rewards...more
On March 10, the California Department of Financial Protection and Innovation closed Silicon Valley Bank and appointed the Federal Deposit Insurance Corporation (FDIC) as its receiver. Silicon Valley Bank had 17 branches in...more
On February 28, the Financial Crimes Enforcement Network of the U.S. Department of Treasury (FinCEN) issued an alert warning financial institutions to be vigilant in identifying and reporting check fraud schemes targeting the...more
As we previously reported on the blog, the Consumer Financial Protection Bureau (CFPB) recently published a proposed rule that would dramatically cut the safe harbor for credit card late fees. In his State of the Union...more
Please join Troutman Pepper Partner Chris Willis and his colleagues Associates Caleb Rosenberg and Josh McBeain as they discuss commercial financing regulatory developments, specifically what is happening in both legislatures...more
On January 27, the Federal Reserve Board (Fed) announced that it denied the application of Custodia Bank, a Wyoming special purpose depository institution (SPDI), for member status on the basis that its novel business model...more
The Federal Deposit Insurance Act (FDIA) generally prohibits insured state banks, but not uninsured state member banks, from acting as principal in activities that are not permissible for national banks. Relying on its...more
In an October 27 letter, the American Bankers Association (ABA) expressed concern regarding a proposal currently being considered by the Consumer Financial Protection Bureau (CFPB) that would shift liability from consumers to...more
On October 6, the New York State Department of Financial Services (NYDFS) announced a consent order with Rhinebeck Bank (Rhinebeck) to resolve allegations that, in violation of New York Executive Law Section 296-a, the bank...more
On September 21 and 22, chief executives from the nation’s seven largest banks faced questioning before Congress, marking the third time senior bank officers have testified before Congress in the last three years. Senators...more
Banking trade groups are challenging a request for information (RFI) issued by the Consumer Financial Protection Bureau (CFPB) regarding customer service at large financial institutions. In a joint letter dated August 22, the...more
In a keynote address at the Consumer Federation of America’s 2022 Consumer Assembly, CFPB Deputy Director Zixta Martinez squarely took aim at “rent-a-bank schemes” in some of the first (if not the first) such comments by a...more