CFPB's Policy Statement on Abusiveness (Part 2) - The Consumer Finance Podcast
Compliance Perspectives: Changes to the Physician Self-Referral and Anti-Kickback Rules
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 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
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
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
On April 3, the CFPB issued a policy statement containing an “analytical framework” for identifying abusive conduct prohibited under the Consumer Financial Protection Act. The Bureau broadly defines abusive conduct as...more
Growing up in New England we both heard that there were three things you should never discuss in public. Politics and religion were two. The third could differ....more
Federal Reserve Issues Policy Statement on Section 9(13) of the Federal Reserve Act - On January 27, the Federal Reserve issued a policy statement interpreting section 9(13) of the Federal Reserve Act, which authorizes...more
The CFPB has begun issuing Consumer Financial Protection Circulars to the government agencies responsible for co-enforcing federal consumer financial law. The Circulars are policy statements that outline how the CFPB intends...more
On March 16, 2022, the Consumer Financial Protection Bureau (CFPB) announced its intent to address discrimination as an “unfair practice” under the Consumer Financial Protection Act (commonly known as Dodd-Frank)....more
In This Issue. Several federal financial regulatory agencies updated their Spring 2021 regulatory agendas; the Consumer Financial Protection Bureau (CFPB) announced its intention to restart Military Lending Act examinations;...more
On June 28, 2021, the Consumer Financial Protection Bureau (CFPB) issued a final rule to amend the mortgage servicing rules in Regulation X, which implements the Real Estate Settlement Procedures Act, to provide additional...more
This month the Consumer Financial Protection Bureau (CFPB) doubled-down on its earlier warning that the end of 2021 could see widespread foreclosures as COVID-19-related protections expire, by issuing guidance to mortgage...more
On April 1, 2021, acting Director of the Consumer Financial Protection Bureau (CFPB), David Uejio, fired a shot across the bow of mortgage servicers in the form of a Compliance Bulletin and Policy Guidance (Bulletin)....more
Another day, another major pronouncement from the Consumer Financial Protection Bureau (CFPB or Bureau), which just took two important actions. First, it rescinded seven different policy statements that offered flexibility to...more
On April 1, 2021, the Consumer Financial Protection Bureau rescinded seven policy statements issued between March 26 through June 3, 2020 that provided temporary relief from certain regulatory obligations during the COVID-19...more
In This Issue. President Biden signed a bill extending the Small Business Administration’s (SBA) Paycheck Protection Program (PPP) through May 31, 2021; the Consumer Financial Protection Bureau (CFPB) announced the rescission...more
On March 11, 2021, the Acting Director of the Consumer Financial Protection Bureau rescinded the CFPB's January 24, 2020 policy statement that had established certain restrictions on how the CFPB will apply its abusiveness...more
In this Issue. The Consumer Financial Protection Bureau (CFPB) announced the rescission of its 2020 Statement of Policy Regarding Prohibition on Abusive Acts or Practices, possibly signaling an increase in enforcement...more
Last week, the Consumer Financial Protection Bureau (CFPB or Bureau) just reversed course on the standard for abusive practices established under prior CFPB leadership. In this short report, we refresh you on the prior formal...more
The Consumer Financial Protection Bureau (CFPB or Bureau) issued a Statement of Policy (Statement) on March 8 making it clear that going forward it will exercise its full authority to penalize covered persons found to have...more
On March 11, 2021, the Consumer Financial Protection Bureau (CFPB or “Bureau”) issued a Rescission of Statement of Policy rescinding its January 24, 2020 Policy Statement regarding the prohibition on abusive acts or practices...more