To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more
The steady drumbeat of steps during Rohit Chopra’s tenure as CFPB Director to call into question the reliability and predictability of medical debt information in credit underwriting reached a crescendo last week with the...more
On June 11, the Consumer Financial Protection Bureau (CFPB or Bureau) released a proposed rule amending Regulation V, which implements the Fair Credit Reporting Act (FCRA), concerning medical debt. The proposed rule would...more
The CFPB announced last week that it has entered into a consent order with Commonwealth Financial Systems, Inc. (Commonwealth), a third-party debt collection company that collects past-due medical debts and furnishes...more
In July, the Consumer Financial Protection Bureau published a report highlighting various unfair, deceptive, and abusive acts or practices it claims to have uncovered during its supervisory examinations from July 2022 to...more
On September 21, 2023, with limited time to digest the comments received by September 11, 2023 from the request for information regarding medical payment products, the Consumer Financial Protection Bureau (CFPB) started the...more
On July 19, 2023, the Consumer Financial Protection Bureau (“CFPB”) sued Snap Finance LLC, Snap R TO LLC, Snap Second Look LLC, Snap U.S. Holdings LLC, and Snap Finance Holdings LLC (collectively, the Snap Defendants or...more
The CFPB announced at the end of last week that it had entered into a consent order with Phoenix Financial Services, LLC (Phoenix), a third-party debt collector that collects primarily past-due medical debts and furnishes...more
On March 3, the CFPB received a rulemaking petition from the National Consumer Law Center (NCLC) in response to forthcoming FCRA rulemaking announced in the Bureau’s Fall 2022 regulatory agenda. As previously covered by...more
The Consumer Financial Protection Bureau (“CFPB”) has issued several statements affecting the credit reporting industry in the last few months, including one on medical debts and one on auto financing, while at the same time...more
As part of the Biden administration’s focus on enforcement of the No Surprises Act (NSA), the Consumer Financial Protection Bureau (CFPB) has issued a bulletin (the Bulletin) indicating that it will closely review the...more
On March 31, the Consumer Financial Protection Bureau (CFPB or Bureau) announced it is rescinding its April 1, 2020 policy statement regarding the Fair Credit Reporting Act (FCRA) and Regulation V following the enactment of...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
On January 5, 2021, the Consumer Financial Protection Bureau’s Taskforce on Federal Consumer Financial Law Report issued a two-volume report on “how to improve consumer protection in the financial marketplace.” The...more
On August 20, the Consumer Financial Protection Bureau (CFPB) entered a consent order with a national bank over the sales and marketing practices for its optional overdraft service called Debit Card Advance (DCA). DCA...more
Since the passage of the Coronavirus Aid, Relief and Economic Security Act (“CARES Act”), Pub. L. 116-136, on March 27, 2020, there has been much uncertainty and confusion arising from that portion of the CARES Act which...more
The CFPB has issued a policy statement concerning COVID-19 considerations that will be relevant to how the CFPB chooses to exercise its supervisory and enforcement authority regarding compliance with the Fair Credit Reporting...more
On April 1, the Consumer Financial Protection Bureau (CFPB) issued a policy statement addressing credit reporting issues faced by consumers and credit furnishers in light of the COVID-19 pandemic....more
The CFPB has issued a special edition of its Supervisory Highlights that focuses on compliance with the FCRA and Regulation V. The report contains two main sections, with one devoted to supervisory observations at furnishers...more
On September 25, 2019, the CFPB filed a lawsuit in federal district court in Maryland against Maryland-based debt collector FCO Holding, Inc. (“FCO”), its various subsidiaries and Michael E. Sobota, the CEO, president,...more
At the end of last week, the CFPB announced that it had entered into a consent order with State Farm Bank, FSB to settle allegations that the Bank violated the Fair Credit Reporting Act...more