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CFPB, FDIC, and OCC Updates: Firings, Appointments, and Potential Consolidation

We previously reported on changes to leadership at the Consumer Financial Protection Bureau (CFPB), the halt of all activities at the CFPB, and the impacts to the financial services industry. The environment continues to...more

New Consumer Financial Protection Bureau Acting Director Expands Freeze to All CFPB Activities; CFPB Office Closes

We previously reported that Treasury Secretary Bessent was named as the acting director of the Consumer Financial Protection Bureau (CFPB), and he subsequently ordered the CFPB staff to halt several activities. However, the...more

Consumer Financial Protection Bureau Proposes Rule to Regulate Data Brokers Under Fair Credit Reporting Act

The Consumer Financial Protection Bureau (CFPB) today announced a proposed new rule that all data brokers be regulated under the 1970 Fair Credit Reporting Act (FCRA), a federal law that protects the use and privacy of credit...more

FTC Finalizes “Click-to-Cancel” Rule 18 October 2024

The Federal Trade Commission (FTC) has finalized amendments to the Negative Option Rule, now retitled the “Rule Concerning Recurring Subscriptions and Other Negative Option Programs“ (“Rule”), which represents a significant...more

Fourth Circuit Holds No Article III Standing Where No Third-Party Viewed Inaccurate Information

On September 11, 2024, the Fourth Circuit Court of Appeals held that there is no publication to a third party — and therefore no Article III standing under the Fair Credit Reporting Act (FCRA) — where the recipient of a...more

What’s Next for Ethereum ETFs Following SEC Approval?

ollowing the approval and launch of Bitcoin Exchange Traded Funds (EFTs) in January 2024, the U.S. Securities and Exchange Commission (SEC) approved eight Ethereum ETFs for listing and trading on SEC-regulated exchanges on...more

Supreme Court Rules That the CFPB Is Constitutionally Funded

On May 16, 2024, the Supreme Court reversed a Fifth Circuit decision which held that the funding for the Consumer Financial Protection Bureau (CFPB) violated the Appropriations Clause. This case was viewed as pivotal to the...more

Legal Decision Expected Today Regarding Implementation of CFPB Rule Reducing Credit Card Late Fees

On March 5, 2024, the Consumer Financial Protection Bureau (CFPB) finalized a rule (“Final Rule”) that would reduce credit card late fees to $8 for large credit card issuers (“Larger Card Issuers”). This rule comes on the...more

CFPB Announces Proposed Rule Regarding Nonsufficient Funds Fees

On Wednesday, January 24, 2024, the Consumer Financial Protection Bureau (CFPB) announced a Proposed Rule aimed at blocking nonsufficient funds (NSF) fees on debit card, ATM, and certain peer-to-peer payment transactions that...more

CFPB Brings RESPA Reminder To Mortgage Comparison Sites

The Consumer Financial Protection Bureau ended a more than decadelong hiatus since the last formal guidance regarding Section 8 of the Real Estate Settlement Procedures Act on Feb. 7 by issuing its advisory opinion aimed at...more

Pay-to-Play in the CFPB’s Cross-Hairs: Digital Mortgage Comparison-Shopping Platforms under RESPA Scrutiny

The Consumer Financial Protection Bureau (CFPB) ended a more than decade-long hiatus since the last formal guidance regarding Section 8 of the Real Estate Settlement Procedures Act (RESPA) on February 7, 2023, by issuing its...more

CFPB's Notice of Proposed Rulemaking

On January 11, 2023, the Consumer Financial Protection Bureau (CFPB) issued a Proposed Rule that will, if adopted, require certain nonbank covered entities—including consumer reporting agencies (CRAs)—to register certain...more

The Consumer Financial Protection Bureau Issues 2022 Annual Report of Credit and Consumer Reporting Complaints

On January 3, 2023, the Consumer Financial Protection Bureau (CFPB) issued its annual report of credit and consumer reporting complaints. The report contains a thorough analysis of how the nationwide consumer reporting...more

What You Need to Know About Automatic Renewals

We live in the age of “Have it fast! Have it now! Have it without hassle!” At the same time customers are demanding ease in online transactions, businesses are naturally seeking to meet consumer demand while reducing...more

When Might the Use of AI, Machine Learning, or Robotic Process-Enabled Insurance Models Result In an Adverse Action under the...

As insurers consider augmenting the quoting process with algorithmic predictive models, including those aided by artificial intelligence, machine learning, and/or robotic process automation (“Models”) for which core inputs...more

FTC Strengthens Data Security Requirements

The Federal Trade Commission (FTC) recently published changes to data security requirements for financial institutions by revising the Safeguards Rule (Rule) under the Gramm-Leach-Bliley Act (GLBA). The law is designed to...more

Courts Hold Contract Disputes Not Actionable Under FCRA

A recent string of U.S. District Court decisions has clarified liability for furnishers of credit information under the Fair Credit Reporting Act (FCRA), specifically 15 U.S.C. § 1681s-2(b), in situations where consumers...more

Supreme Court Rules Injury at Law Insufficiently Concrete to Establish Injury in Fact

On Friday morning, the Supreme Court issued its eagerly awaited opinion in TransUnion LLC v. Ramirez (No. 20-297). Justice Kavanaugh delivered the opinion of the Court, with which four Justices concurred; Justices Thomas,...more

A Reminder that Power Purchase Agreements may be Subject to Consumer Protection Laws

With the growth of residential renewable energy power generation, driven in part by a rise in the use of Power Purchase Agreements (“PPAs”), compliance with consumer laws and regulations is critical. PPAs permit solar...more

Creditors Must Continue to Take Proper Care under the CARES Act

Recently, the Consumer Financial Protection Bureau (CFPB) issued a compliance aid that addresses frequently asked questions related to the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) and the COVID-19...more

Twin Ninth Circuit Opinions Clarify FCRA Disclosure Requirements for Employers

The Fair Credit Reporting Act (FCRA) can at times present a minefield for employers across industries to navigate when it comes to consumer reports used in candidate and employee background checks. The FCRA permits employers...more

COVID-19: Privacy and Cybersecurity Regulatory and Enforcement Guidance (Updated)

On March 19, 2020, the European Data Protection Board (EDPB) adopted a statement on the processing of personal data in the context of the COVID-19 outbreak. The EDPB made it clear that while the EU’s General Data Protection...more

COVID-19: Privacy and Cybersecurity Regulatory and Enforcement Guidance

As industry continues to adapt to the evolving realities of shelter-in-place orders, companies face challenges in supporting an unprecedented remote workforce while balancing compliance with a variety of regulatory agencies....more

“Stand-Alone” REALLY Does Mean Stand-Alone - Ninth Circuit Court of Appeals Interprets the FCRA

On January 29, 2019, the U.S Court of Appeals for the Ninth Circuit (covering a number of states and territories bordering the Pacific Ocean) issued a far-reaching opinion that will likely impact the hiring process of...more

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