On January 13, the CFPB published a report analyzing consumers’ use of Buy Now, Pay Later (BNPL) loan products. This latest report builds on previous CFPB work related to BNPL lending by pairing a matched sample of BNPL...more
Recent Consumer Financial Protection Bureau ("CFPB") guidance reiterates that creditors must provide consumers with accurate and individualized explanations for adverse actions—a task made more difficult by the complexity of...more
Crazy times, right? Chances are you've heard this refrain numerous times over the last seven months, most notably on Zoom calls during the crushing silence of someone on the call forgetting to unmute his or her microphone....more
Alert May 18, 2020 The economic impact of COVID-19 has already proven catastrophic for many businesses and consumers. Many employers are reducing their staffing or closing their doors permanently. As of May 8, 2020, the...more
Regulatory uncertainty remains one of the most significant challenges to finance companies that want to develop creative and innovative products and services. Federal and state agencies have implemented policies to facilitate...more
The OCC, Federal Reserve Board, FDIC, NCUA and CFPB have issued an “Interagency Statement on the Use of Alternative Data in Credit Underwriting.”...more
The Consumer Financial Protection Bureau (CFPB) has stepped up its enforcement actions alleging deceptive and unfair practices in marketing and billing for add-on credit protection products. Add-on products have been one of...more