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No Safe Harbor for Inaccurate Adverse Action Notices Based Upon Undisclosed Use of AI and Complex Credit Models

The Consumer Financial Protection Bureau (CFPB) issued a circular on September 19, 2023, addressing its concerns about a creditor’s use of artificial intelligence or complex credit models to review and make decisions...more

Consumer Financial Protection Bureau Issues “Zombie Mortgage” Advisory Opinion

The Consumer Financial Protection Bureau (CFPB) issued an advisory opinion last month to affirm that the Fair Debt Collection Practices Act (FDCPA) and its implementing Regulation F prohibit a debt collector, as that term is...more

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