News & Analysis as of

Disclosure Requirements Fees Financial Services Industry

Ballard Spahr LLP

CFPB proposed rule would makes certain overdraft program’s credit subject to Regulation Z disclosure requirements and could cap...

Ballard Spahr LLP on

In furtherance of the Biden Administration’s “junk fee” agenda, on January 17, 2024, the Consumer Financial Protection Bureau issued its proposed rule to amend Regulations E and Z to regulate overdraft services provided by...more

Troutman Pepper

CA DFPI Reaches Settlement with Internet Platform Over Alleged Failure to Disclose Potential Convenience Fees

Troutman Pepper on

On January 9, the California Department of Financial Protection and Innovation (CA DFPI) announced a consent order with Credova Financial, LLC, (Credova) to resolve allegations that, in violation of the California Consumer...more

Troutman Pepper

Massachusetts Proposes Fee Disclosure Regulations Targeting “Junk Fees” and Automatic Renewal Contracts

Troutman Pepper on

On November 30, Massachusetts Attorney General Andrea Joy Campbell announced proposed regulations that would require businesses to clearly disclose the total price of a product at the time it is presented to consumers,...more

Morrison & Foerster LLP

Uncharted Territory: California DFPI Finalizes Commercial Financing UDAAP Regulations

The California Department of Financial Protection and Innovation (DFPI) finalized regulations that prohibit unfair, deceptive, and abusive acts and practices (UDAAP) in the offering or provision of commercial financing or...more

Sheppard Mullin Richter & Hampton LLP

Consumer Fees Find Themselves in the Crosshairs: The CFPB Seeks Public Input on Alleged “Junk Fees” in the Consumer Financial...

The Consumer Financial Protection Bureau (“CFPB”) has continued to ratchet up its regulatory scrutiny over the consumer financial services market. On January 26, 2022, the CFPB published an initiative seeking public input on...more

Goodwin

Agencies Publish Notice and Request for Comment on Proposed Interagency Guidance on Third-Party Relationships

Goodwin on

In This Issue. The federal bank regulatory agencies requested public comment on proposed guidance designed to help banking organizations manage risks associated with third-party relationships; the Office of the Comptroller of...more

BCLP

The SEC’s Division of Examinations Highlights Increased Concerns with Wrap Fee Programs

BCLP on

Given the continued popularity of recommending wrap fee programs to clients, the Securities and Exchange Commission’s (“SEC”) Division of Examinations (“DOE”) recently released a Risk Alert dated July 21, 2021, wherein it...more

Goodwin

Financial Services Weekly Roundup: SEC Proposes Modified Disclosure Framework For Funds

Goodwin on

In the News. The Securities and Exchange Commission (SEC) proposed modifying the disclosure framework for mutual funds and exchange-traded funds (funds), which would create a new layered disclosure regime that attempts to...more

Goodwin

Financial Services Weekly Roundup: The Supreme Court Strikes Back On Single Director Leadership Structures

Goodwin on

In This Issue. The U.S. Supreme Court struck down the single director leadership structure of the Consumer Financial Protection Bureau (CFPB) in a ruling that could have far-reaching implications for the CFPB and other...more

Carlton Fields

New York Pushes Mutual Fund Active Share Disclosure

Carlton Fields on

New York’s Attorney General issued a report on its recent investigation of fees charged by actively managed equity mutual funds and a metric known as "Active Share." Denoted as a "percentage" from 0 to 100 percent, Active...more

Smith Debnam Narron Drake Saintsing & Myers,...

Consumer Financial Services Spring 2018 Update

District Court Takes Expansive View of Deceptive or Misleading Practices under FDCPA - The FDCPA prohibits a debt collector from using "any false, deceptive, or misleading representation" in connection with the collection...more

Smith Debnam Narron Drake Saintsing & Myers,...

Second Circuit Seeks to Provide Clarity as to Interest Disclosure

The Seventh Circuit recently joined the Fourth and Ninth Circuits in holding that a debt collection discharges its obligation as to debt validation by verifying that its letters accurately conveyed the information received...more

Ballard Spahr LLP

CFPB’s Prepaid Card Rule: Short Form Disclosure Requirements

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The CFPB’s Final Rule on prepaid cards includes, in addition to the long form disclosure requirements discussed in our November 21st blog post, highly detailed requirements for providing “preacquisition” disclosures to...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

Financial Industry Developments - The CFPB Publishes Final Rule for Prepaid Accounts - On October 5, 2016, the Consumer Financial Protection Bureau (the "CFPB") finalized comprehensive consumer protections for...more

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