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Litigation Byte (October Edition)

Delivered in digestible, insightful bites, McGlinchey’s Litigation Byte is a monthly roundup of financial services decisions and cases nationwide that impact your business. 4th Circuit Holds Rental Applicant Lacks Standing...more

FCRA Claims Fail as Mortgagor Could Not Satisfy His Repayment Obligations by Tendering Another Promise to Pay

On September 19, 2024, the District Court for the Eastern District of New York dismissed claims against the mortgage lender, its mortgage servicer, and credit reporting agencies under the Fair Credit Reporting Act (FCRA), 15...more

Litigation Byte (September Edition)

Court Finds Mass Arbitration Bellwether and Delegation Provisions Unconscionable - The district court for the Northern District of California recently denied a defendant’s motion to compel arbitration and, in so ruling,...more

FCRA Action Dismissed for Lack of Standing and Failure to State a Claim

In July 2024, the United States Court for the District of Massachusetts dismissed a pro se litigant’s claims against Experian Information Services LLC (Experian), TransUnion LLC (TransUnion), and Equifax Information...more

CFPB Proposes New Rules Aimed at “Streamlining” Mortgage Servicing

On July 10, 2024, the Consumer Financial Protection Bureau (CFPB or Bureau) proposed a rule it says will streamline mortgage servicing and the loss mitigation process. If enacted, the proposed rule would significantly revise...more

New York’s Interest-On-Escrow Law May Not Be Preempted by the National Bank Act

On May 30, 2024, the Supreme Court reversed the Second Circuit’s holding that New York General Obligation Law § 5–601, which mandates banks to pay borrowers the interest accumulated on a balance held in an escrow account for...more

CFPB Warns: “Unlawful” or “Unenforceable” Terms in Form Contracts Can Violate CFPA

On June 4, 2024, the Consumer Financial Protection Bureau (CFPB) issued a Circular warning companies that the inclusion of “unlawful” or “unenforceable” terms in a form contract constitutes a deceptive act or practice in...more

CFPB Poised To Up The Ante After Supreme Court Victory

This is the second part of a two-part series on Consumer Financial Protection Bureau v. Community Financial Services Association of America. Read part one here. In what should not come as a surprise to anyone who observed...more

CFPB Supervisory Highlights Reflect Continued Emphasis on “Junk Fees”

On April 24, 2024, the Consumer Financial Protection Bureau (CFPB) released the latest edition of its Supervisory Highlights, this time targeting so-called “junk fees” in the mortgage servicing industry. According to the...more

CFPB’s So-Called “Junk Fees” Revolution Targets Residential Mortgage Loan Closing Costs

On March 8, 2024, the Consumer Financial Protection Bureau (CFPB) announced it was seeking public input on so-called “junk fees” incurred as part of the closing process for residential mortgage loans. The residential...more

“Junk Fee” Revolution Continues: CFPB Issues Final Rule Limiting Late Fees on Credit Cards

Tuesday, the Consumer Financial Protection Bureau (CFPB) issued a Final Rule capping most credit card late fees at $8. The CFPB believes its new rule may save consumers more than $10 billion a year in late fee charges for an...more

Junk Fee Supervisory and Enforcement Activity Targets Auto Servicers

For almost two years, the Consumer Financial Protection Bureau (CFPB) has made combating so-called junk fees an agency priority, bringing multiple enforcement actions, undertaking supervisory activity, and collaborating with...more

Clues On High Court Outcome In CFPB Constitutionality Case

On October 3, the U.S. Supreme Court heard oral arguments in the Consumer Financial Protection Bureau v. Community Financial Services Association of America, the latest in a long line of cases targeting the constitutionality...more

The Fuss About Junk Fees, Pt. 3: Defending Junk Fees Litigation and Regulatory Oversight

In this three-part series, we first reviewed the Biden Administration’s collaborative efforts with the CFPB and the FTC to regulate “junk fees.” We highlighted recent regulatory, enforcement, and private actions and trends in...more

The Fuss About Junk Fees, Pt. 1: Biden, CFPB, and FTC Collaborate

Anyone who has financed the purchase of a good or service, had a bank account, bought a car, or purchased sporting event tickets has almost assuredly encountered what the Biden Administration and various regulatory agencies...more

Did I waive the terms of my contract? - McGlinchey Commercial Law Bulletin - July 8, 2022

Fair Debt Collection Practices Act- In this appeal, the Court of Appeals for the Sixth Circuit reversed and remanded the District Court for the Northern District of Ohio’s decision, finding the debt collector violated the...more

CFPB Eyes Unfair, Deceptive Acts: Here Are Some Tips To Avoid Scrutiny

With a new administration comes new priorities for federal agencies, and the Consumer Financial Protection Bureau (CFPB) is no different. During the Trump administration, the Bureau focused on “educating” consumers. Under...more

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