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CFPB Comments on AI Offer Insights for Consumer Finance Industry

On August 12, 2024, the Consumer Financial Protection Bureau (CFPB or Bureau) provided comments on the use of artificial intelligence (AI) in the financial services sector that are among its most extensive regarding risks and...more

US Banking Agencies Are Ramping Up Scrutiny of Bank-Fintech Partnerships

On July 25, 2024, the U.S. prudential bank regulators released a Joint Statement on Banks’ Arrangements With Third Parties To Deliver Bank Deposit Products and Services (Joint Statement),1 along with a request for information...more

CFPB Applies Credit Card Rules to 'Buy Now, Pay Later' Lenders

Following its recent win before the Supreme Court, the Consumer Financial Protection Bureau (CFPB or Bureau) on May 22, 2024, issued an interpretive rule concluding that “Buy Now, Pay Later” (BNPL) loans accessed through a...more

CFPB Applies Adverse Action Notification Requirement to Artificial Intelligence Models

As technology continues to advance, regulators are increasingly addressing the fair lending implications of artificial intelligence (AI), even though comprehensive rules governing AI have yet to be promulgated. Notably, the...more

House Bill To Revise Community Reinvestment Act Would Put New Focus on Fair Lending

Legislation introduced on September 15, 2022 by Maxine Waters (D-Cal.), chair of the House Committee on Financial Services, would significantly revise the Community Reinvestment Act (CRA), adding a number of new substantive...more

District Court Upholds OCC and FDIC ‘Valid When Made’ Rules

On February 8, 2022, a federal district court in California issued two opinions, granting summary judgment to the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) and...more

Racial Equity and Fair Lending at the Forefront of Consumer Financial Services Enforcement

The Biden administration has moved quickly on its promise to take a more aggressive approach to pursuing actions against consumer financial services companies. Though the administration has implemented some concrete policy...more

Consumer Financial Protection Bureau Launches Advisory Opinion Process

On June 18, 2020, the Consumer Financial Protection Bureau (CFPB or Bureau) announced the pilot of a new Advisory Opinion process, offering a potentially useful tool for those seeking guidance on compliance issues. ...more

Summary of 28th Annual Conference on Fair Lending and Consumer Financial Protection

Year In Review - Anand Raman, the head of Skadden’s Consumer Financial Services (CFS) practice, began the conference by providing a summary of notable events and trends over the past year relating to consumer financial...more

"Limited English Proficiency: An Emerging Compliance Risk"

How consumer financial services providers can meet the needs of a growing population of "limited English proficiency" (LEP) consumers without running afoul of laws prohibiting deceptive practices and discrimination has...more

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