News & Analysis as of

Insufficient Funds Financial Regulatory Reform

Ballard Spahr LLP

Minnesota federal court dismisses lawsuit against FDIC over NSF fee guidance

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On April 8, 2024, a Minnesota federal district court dismissed without prejudice the complaint filed by the Minnesota Bankers Association and Lake Central Bank (Plaintiffs) against the Federal Deposit Insurance Corporation...more

Cadwalader, Wickersham & Taft LLP

CFPB Again Seeks Demise of Overdraft or NSF Fees, Part 1

In January 2024, the Consumer Financial Protection Bureau ("CFPB") issued two proposed rules that, if implemented as written, would result in further whittling down overdraft or non-sufficient funds ("NSF") fees charged by...more

Venable LLP

Declined: CFPB Proposes Rule to Limit Non-Sufficient Funds Fees

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One week after the CFPB published its proposed rule restricting overdraft fees, the CFPB proposed yet another rule prohibiting nonsufficient funds fees (NSF fees) on transactions like declined debit card purchases and...more

Troutman Pepper

CFPB Continues War on Fees, Even Rare Ones

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Last week, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a proposed rule with request for public comment to prohibit covered financial institutions from charging nonsufficient funds fees (NSF) for payment...more

Ballard Spahr LLP

CFPB proposes rule to ban “rarely charged” NSF fees for declined transactions based on wildly expansive view of “abusive” prong

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On January 24, 2024, a week after issuing its proposed rulemaking for overdraft services, the Consumer Financial Protection Bureau (“CFPB”) issued its proposed rulemaking on non-sufficient funds (NSF) fees....more

Ballard Spahr LLP

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

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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

New Year Same Focus on Fees: CFPB Proposes to Amend Regulation Z to Raise New Barriers to Overdraft Charges

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On January 17, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a proposed rule with request for public comment to amend exemptions to Regulation Z so the Truth in Lending Act (TILA)/Regulation Z would apply...more

Ballard Spahr LLP

CFPB’s credit card late fee final rule and overdraft and NSF fee proposed rulemaking expected prior to President Biden’s March 7th...

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Speaker of the House Mike Johnson (R-LA) has invited President Joe Biden to give his State of the Union address to a Joint Session of Congress on Thursday, March 7, 2024. The invitation was immediately accepted by President...more

Ballard Spahr LLP

CBA launches overdraftfacts.com to provide insights to policymakers

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On January 8, 2024, the Consumer Bankers Association (CBA) announced the launch of a new microsite, overdraftfacts.com, to demonstrate the value overdraft services provide to consumers, highlight bank-driven overdraft and...more

Ballard Spahr LLP

CFPB issues report to bolster its imminent overdraft and NSF fee rulemaking

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As we await the CFPB’s proposed overdraft and nonsufficient funds (NSF) fee rule, the CFPB issued another report, Overdraft and Nonsufficient Fund Fees: Insights from the Making Ends Meet Survey and Consumer Credit Panel. It...more

Troutman Pepper

CFPB Report Highlights Consumer Experiences with Overdraft and NSF Fees

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On December 19th, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a report highlighting consumers’ experiences with overdraft and nonsufficient funds (NSF) fees. The report found that roughly a quarter of...more

Ballard Spahr LLP

CFPB reported to be planning to unveil overdraft regulations before year-end

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Last week, Bloomberg Law reported that “Consumer Financial Protection Bureau officials have privately told industry executives that the regulator will likely unveil its long-awaited plan to crack down [on overdraft fees] in...more

Troutman Pepper

October 11 Was a Red-Letter Day in the Growing Federal-State War on Fees

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On October 11, the Consumer Financial Protection Bureau (CFPB or Bureau) published a special edition of its Supervisory Highlights report. This report serves as a “victory lap” for the Bureau, which highlights the relief it...more

Moore & Van Allen PLLC

Suit Alleging FDIC Overdraft Overreach May Not Make Waves

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When following supervisory scrutiny of fees charged to bank customers, the activities of the Consumer Financial Protection Bureau, or CFPB, are often the focus. The Minnesota Bankers Association and Lake Central Bank of...more

Ballard Spahr LLP

CFPB Spring 2023 rulemaking agenda includes proposed larger participant rule for nonbanks in consumer payments market

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The CFPB has released its Spring 2023 rulemaking agenda as part of the Spring 2023 Unified Agenda of Federal Regulatory and Deregulatory Actions.  The agenda’s preamble indicates that “[t]he Bureau reasonably anticipates...more

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