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Proposed Rules Consumer Financial Products Rulemaking Process

Troutman Pepper

Highlights from the CFPB’s Spring 2024 Semi-Annual Regulatory Agenda

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The Consumer Financial Protection Bureau (CFPB or Bureau) recently released its semi-annual regulatory agenda, outlining its planned rulemaking initiatives. The CFPB releases regulatory agendas twice a year in voluntary...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’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

Comment letters from consumer advocates bolster case against CFPB rulemaking on post-dispute arbitration clauses

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We previously reported and released a podcast episode on comments that we and Professor David Sherwyn of Cornell University submitted in opposition to the Petition for Rulemaking filed by a number of consumer advocacy groups...more

Ballard Spahr LLP

Trade groups urge CFPB to issue ANPR on FCRA rulemaking

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In September 2023, the CFPB announced that it was launching a Fair Credit Reporting Act rulemaking and issued an outline of the proposals it is considering in preparation for convening a Small Business Advisory Review Panel. ...more

Ballard Spahr LLP

Ballard Spahr attorneys and Cornell University law professor submit comments opposing CFPB rulemaking on post-dispute consumer...

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Ballard Spahr Senior Counsel Alan S. Kaplinsky and Mark J. Levin, and David Sherwyn, Professor of Law at Cornell University’s School of Hotel Administration, today submitted lengthy comments to the Consumer Financial...more

Troutman Pepper

CFPB Outlines Rulemaking Plan to Dramatically Alter Decades of FCRA Requirements for Everyone in the Consumer Data Ecosystem

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The Consumer Financial Protection Bureau (CFPB) has started the process of issuing rules on several topics affecting the entire ecosystem that collects, sells, and uses data about consumers, according to an Outline of the...more

Sheppard Mullin Richter & Hampton LLP

Latest CFPB Rule Proposal Takes Aim at Credit Card Late Fees

On February 1, the CFPB announced a newly proposed rule aimed at ensuring that late fees charged on consumer credit card accounts are “reasonable and proportional” to late payments. If finalized, the proposed rule would amend...more

Sheppard Mullin Richter & Hampton LLP

DFPI Issues Proposed Rules for Commercial Financing

On June 24, the California Department of Financial Protection and Innovation (DFPI) issued proposed regulations implementing certain provisions of the California Consumer Financial Protection Law (CFPL) related to commercial...more

Morgan Lewis

Protecting Your Investment: Insights For 2020

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Investors and investment managers around the globe are seeing increasing rules and regulations on how they can deploy their money, how they can advertise their services, and how they have to report to regulators. ...more

Smith Debnam Narron Drake Saintsing & Myers,...

CFPB’s Rulemaking Agenda Provides Glimpse into 2020

The CFPB’s 2020 Rulemaking Agenda provides a preview of the Bureau’s intended rulemaking activities for 2020. Here are the highlights of what we can look forward to in 2020: Business Lending Data (Pre-rule Stage): Under...more

Ballard Spahr LLP

CFPB Issues Final HMDA Rule (2019 Update)

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The CFPB recently issued in final form two elements of a May 2019 Home Mortgage Disclosure Act (HMDA) proposed rule. As previously reported, the May 2019 proposal would...more

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Consumer Bankers Association comments on CFPB’s proposed debt collection rule

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The Consumer Bankers Association (CBA) has filed a letter commenting on the CFPB’s proposed debt collection rule. Ballard Spahr served as counsel to the CBA in preparing the comment letter....more

Ballard Spahr LLP

CFPB Reopens HMDA Proposed Rule Comment Period

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The CFPB recently announced that it is reopening the comment period for the May 2019 Home Mortgage Disclosure Act (HMDA) rule proposal. Comments on certain aspects of the proposal, addressed below, are due by October 15,...more

Ballard Spahr LLP

HMDA Proposed Rule Comment Period

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As previously reported, in May 2019 the CFPB issued both a proposed rule to modify the existing Home Mortgage Disclosure Act (HMDA) rule and an advance notice of proposed rulemaking seeking comment on additional potential...more

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Mortgage-specific provisions in the CFPB’s proposed debt collection rules

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Continuing our coverage of the CFPB’s proposed debt collection rules, this blog post will focus on a few provisions that pertain specifically to mortgage servicers. ...more

Burr & Forman

The CFPB’s Proposed Debt Collection Rules and The Impact on First-Party Collectors

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On May 7, 2019, the Consumer Financial Protection Bureau (“Bureau” or “CFPB”) issued a Notice of Proposed Rulemaking (“NPRM”) to implement the Fair Debt Collection Practices Act (“FDCPA”). The full NPRM is 538 pages and can...more

Ballard Spahr LLP

CFPB’s proposed debt collection rules published in Federal Register

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The CFPB’s proposed debt collection rules were published in Tuesday's Federal Register....more

Ballard Spahr LLP

Why creditors and servicers should care about the CFPB’s proposed debt collection rules

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The Bureau’s proposed debt collection rules, released last week, only apply to debt collectors, as defined under the Fair Debt Collection Practices Act.  So, why should creditors and servicers be interested in them?  Lots of...more

Ballard Spahr LLP

CFPB publishes debt collection proposed rule

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The CFPB has published its long-awaited notice of proposed rulemaking under the Fair Debt Collection Practices Act (FDCPA). ...more

Ballard Spahr LLP

Department of Defense Proposes Data Sharing Arrangement with Department of Education to Identify Service Members Eligible for 0%...

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A Federal Register entry published last week details a proposed data-sharing arrangement between the Department of Defense (DoD) and the Department of Education (DoE) designed to reduce the amount of interest that certain...more

Ballard Spahr LLP

CFPB proposes revisions to final payday/auto title/high-rate installment loan rule

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The CFPB has issued highly-anticipated proposed revisions to its final payday/auto title/high-rate installment loan rule (Rule) that would rescind the Rule’s ability-to-repay provisions in their entirety (which the CFPB...more

Goodwin

CFPB Seeks Public Comment to Proposed Rule Reforming No-Action Letter Policy

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On December 13, 2018, the CFPB published a proposed rule, seeking public comment regarding a change to its policy on No-Action Letters, as well as a new feature called the “Product Sandbox,” a rule change that was initially...more

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