CFPB's Policy Statement on Abusiveness (Part 2) - The Consumer Finance Podcast
Compliance Perspectives: Changes to the Physician Self-Referral and Anti-Kickback Rules
The Financial Ombudsman Service (FOS) has published a policy statement on its new fee rules regarding complaints that are referred to it by certain claims management companies (CMCs) and other professional representatives...more
On January 10, 2025, the Consumer Financial Protection Bureau (CFPB) revived its policy statements on No-Action Letters (NALs) and Compliance Assistance Sandbox (CAS) Approvals. These unexpected changes come just days before...more
The Bank of England has published a statement of policy setting out its approach to determining commercially reasonable payments to clearing members whose contracts are subject to a statutory tear up in CCP resolution,...more
The U.K. Financial Conduct Authority has published a policy statement on further temporary changes to handling rules for motor finance complaints. The FCA has extended the time motor finance firms have to respond to motor...more
The U.K. Prudential Regulation Authority has published its final policy statement and statement of policy relating to the definition of an Interim Capital Regime firm and an ICR consolidation entity. The policy statement...more
The Payment Systems Regulator has published a policy statement confirming the maximum level of Authorized Push Payment scam reimbursement. The statement follows the PSRs recent announcement confirming its decision to reduce...more
HM Treasury has published a policy statement on the treatment of overseas investment exchanges for the purposes of the U.K. Capital Requirements Regulation. HM Treasury initially proposed to expand the definition of...more
purred by increased online and mobile app shopping during the COVID-19 pandemic, the Buy Now, Pay Later (BNPL) market has experienced higher growth and popularity as an innovative consumer finance offering, particularly for...more
The U.K. Prudential Regulation Authority has published a policy statement on its approach to rule permissions and waivers. The policy statement provides feedback to responses the PRA received to CP3/24 published in January....more
Under the revised U.K. rules, from August 1, 2024, third-party research will not be an inducement if it is received in return for one of the following: The FCA has confirmed that research services are not a factor in...more
On April 20, 2024, the Pennsylvania Department of Banking and Securities (“DoBS”) issued a policy statement (“Policy Statement”) to “clarify” that the Department’s interpretation of the term “money” in the Pennsylvania Money...more
The CFPB has issued a policy statement that provides an analytical framework for identifying what constitutes an abusive act or practice under the Consumer Financial Protection Act of 2010 (CFPA). The new guidance published...more
In 2023, the digital asset industry demonstrated remarkable resilience amidst significant challenges, including the dissolution of several digital asset financial services companies, numerous bank failures, and a $4.7 billion...more
Today, a divided Federal Deposit Insurance Corporation’s (FDIC) Board of Directors issued a proposed Statement of Policy (SOP) on bank merger transactions that would create a combined bank with more than $100 billion in...more
Volume 4, Issue 2, 2024 Welcome! Welcome to the second issue of Promissory Notes - our banking and finance e-newsletter - for 2024. Business today is characterized by relentless change. To assist our clients in navigating...more
The Situation: On January 29, 2024, the Office of the Comptroller of the Currency ("OCC") requested comment on a proposed rule updating its bank merger rules and incorporating a policy statement (the "Proposal") on agency...more
On January 29, the Office of the Comptroller of the Currency (OCC) issued a notice of proposed rulemaking regarding its review of business combinations under the Bank Merger Act (BMA). Specifically, the OCC proposed: (i)...more
The Ontario Securities Commission (“OSC”) recently published its proposed Statement of Priorities for 2024-2025 (the “Statement”), outlining the initiatives on which the OSC intends to focus its resources and actions over the...more
On 28 November 2023, the UK's Financial Conduct Authority ("FCA") published its "Sustainability Disclosure Requirements ("SDR") and investment labels" policy statement (PS23/16) (the "Policy Statement"). The Policy Statement...more
What Is the Consumer Duty? To recap, a core priority for the Financial Conduct Authority (FCA) is improving outcomes for consumers. The FCA has stated that it is concerned that, due to the way financial services markets...more
On April 3, 2023, the Consumer Financial Protection Bureau issued a policy statement on "abusive" practices. While this is the second time the CFPB has issued a policy statement on abusiveness, the significance of this policy...more
On April 3, 2023, the Consumer Financial Protection Bureau (CFPB or “Bureau”) issued new guidance about what constitutes an abusive act or practice under the Consumer Financial Protection Act (the “Policy Statement”). This...more
On April 3rd, the Consumer Financial Protection Bureau issued a new Policy Statement ("Policy") providing an analytical framework to identify "abusive" conduct. This is the second time the CFPB has issued a Policy Statement...more
On April 3, 2023, the Consumer Financial Protection Bureau (CFPB) issued a policy statement on its interpretation of the prohibition on abusive conduct under the Consumer Financial Protection Act (CFPA). Director Rohit Chopra...more
The Consumer Financial Protection Bureau (CFPB) released a second iteration of its Policy Statement on Abusive Acts and Practices (Policy Statement) on April 3, 2023, giving insight into its current thinking on the...more