Can digital comparison-shopping operators or lead generators violate the Consumer Financial Protection Act (CFPA) by preferencing products or services based on financial benefit? According to today’s guidance issued by the...more
On April 3, the CFPB issued a policy statement intended to provide “a framework to help federal and state enforcers identify when companies engage in abusive conduct.” Conduct violates the abusiveness standard when it either:...more
On April 3, 2023, the CFPB published a new official statement of policy on the authority that Congress passed in the Consumer Financial Protection Act of 2010 (“CFPA”), codified at 12 U.S.C. § 5536(a)(1)(B), banning “abusive...more
Last week, the Consumer Financial Protection Bureau (CFPB or Bureau) just reversed course on the standard for abusive practices established under prior CFPB leadership. In this short report, we refresh you on the prior formal...more
The Consumer Financial Protection Bureau (CFPB or Bureau) issued a Statement of Policy (Statement) on March 8 making it clear that going forward it will exercise its full authority to penalize covered persons found to have...more
The Consumer Financial Protection Bureau (the Bureau) recently issued an official policy statement (Policy) that illuminates how the Bureau will apply the Dodd-Frank Wall Street Reform and Consumer Protection Act’s...more
Last week, the CFPB released a long-anticipated policy statement clarifying the agency’s enforcement standard for “abusive acts or practices.” According to an agency press release, the CFPB’s new standard offers a...more
In an effort to promote compliance and certainty, the Consumer Financial Protection Bureau (CFPB or Bureau) on January 24 issued an often promised and much anticipated policy statement regarding how it intends to apply the...more
The CFPB has issued a policy statement to clarify the Dodd-Frank Act’s abusiveness standard. The policy statement, which is applicable as of January 24, 2020, states that it describes “certain aspects of how [the Bureau]...more
On June 25, 2019, the Consumer Financial Protection Bureau (Bureau) hosted the first in a series of scheduled symposia, which explore the Dodd-Frank Act's prohibition on abusive acts or practices. Whether "abusive" requires...more
Having announced in April 2018 that it would be holding a symposia series, the CFPB has now set a date for the first symposium of the series. The first symposium, to be held on June 25, 2019, will focus on the Dodd-Frank...more
In its blog post announcing the Fall 2018 Rulemaking Agenda, the CFPB announced that it is “considering how rulemaking may be helpful to further clarify the meaning of ‘abusiveness’ under the section 1031 of the Dodd-Frank...more
The crux of the CFPB’s “abusive act or practice” claim[1] against Nationwide Biweekly Administration, Inc. (“Nationwide”) is that its customers do not understand how long they must remain in the company’s Interest Minimizer...more