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Consumer Financial Protection Bureau (CFPB) Banking Sector Administrative Procedure Act

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - April 2024 # 5

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Orrick, Herrington & Sutcliffe LLP

OCC and FDIC Successfully Defend Valid-When-Made Rules

The Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) have successfully defended their respective valid-when-made rules. On February 8, 2022, Judge Jeffry S. White, U.S....more

Kilpatrick

State Attorneys General Criticize the CFPB’s Proposal to Create a Fintech Regulatory Sandbox and Revise its No-Action Letter...

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We have previously reported on the initiatives of the Consumer Financial Protection Bureau (CFPB or Bureau) to foster innovation in the fintech sector. In December 2018, the CFPB issued proposed revisions to its 2016 final...more

Kilpatrick

5 KEY TAKEAWAYS: The State of the CFPB’s Small Dollar Rule

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Kilpatrick Townsend’s Sam Arora recently presented at the Texas Organization of Financial Service Centers’ (TOFSC) Annual Conference on “CFPB: Updates on Litigation re: Small Dollar Loans”. The TOFSC was attended by many of...more

Ballard Spahr LLP

Senator Graham introduces CRA resolution to overturn CFPB payday loan rule; Mulvaney to testify on April 11 to House Financial...

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The American Banker has reported that last week, Senator Lindsey Graham introduced a joint resolution under the Congressional Review Act (CRA) to override the CFPB’s final payday/auto title/high-rate installment loan rule...more

Ballard Spahr LLP

CFPB seeks comment on rulemaking processes

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The CFPB has issued a request for information that seeks comment on its rulemaking processes.  Comments on the RFI must be received no later than 90 days after it is published in the Federal Register, which the CFPB expects...more

Ballard Spahr LLP

More details on finance industry’s CFPB arbitration rule lawsuit

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As promised previously, here are further details on the lawsuit filed by industry groups against the CFPB to overturn the final arbitration rule.  The complaint largely mirrors our heavy criticism of the rule. ...more

K&L Gates LLP

The Post-Election FinTech World: Are Happy Days (for Bankers) Here Again?

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In the days following the U.S. federal elections that resulted in the election of Donald Trump as President and Republican control of the 115th Congress, FinTech companies, banks, and other financial institutions are...more

Ballard Spahr LLP

Trade groups oppose CFPB’s proposed expansion of consumer complaint feedback

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The Consumer Bankers Association and the American Bankers Association have submitted a comment letter setting forth their opposition to the CFPB’s proposed addition of a survey to the current complaint intake form....more

Carlton Fields

Notice and Comment Like a Rock Star

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Musicians know they’ve created a hit when thirty-somethings have known all the song’s words since middle school. Likewise, most consumer finance lawyers recall verbatim Regulation Z’s guidance to lenders that, “The annual...more

Burr & Forman

PHH Wins Stay of $109M CFPB Enforcement Penalty

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On August 5, 2015, PHH Corp. (“PHH”) won a stay of the $109M penalty handed down by Consumer Financial Protection Bureau (“CFPB”) director Rich Cordray. Cordray’s aggressive legal reasoning and the harsh penalties he imposed,...more

Pillsbury Winthrop Shaw Pittman LLP

CFPB's Arbitration Study—A Warning to Consumer Financial Service Companies

On December 12, 2013, the Consumer Financial Protection Bureau published its “Arbitration Study Preliminary Results,” mandated by Section 1028(a) of the Dodd-Frank Act (the “Study”). Unfortunately (and despite its statements...more

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