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Chris Friedman is a regulatory compliance attorney and litigator who focuses on helping consumer finance companies and small business lenders, as well as banks, fintech companies, and other participants in the financial services industry, address the challenges of operating in a highly regulated sector. Chris focuses on both small business lenders and alternative business finance products and has helped non-bank small business lenders, banks who make small business loans, commercial credit counselors, lead generators, and others in the industry. He helps clients launch new products, conduct due diligence, engage in compliance reviews, evaluate litigation risk, and solve some of the unique legal problems faced by companies who work with small businesses. In that vein, Chris has written extensively about the upcoming rulemaking related to Dodd-Frank 1071, which will require data collection and reporting by companies making loans to certain small businesses.

On July 27, 2022, the Consumer Financial Protection Bureau (CFPB) and the United States Department of Justice (DOJ) filed a complaint in the United States District Court for the Eastern District of Pennsylvania against Trident Mortgage Company LP for alleged discrimination against minority families in the greater Philadelphia area.

According to the CFPB’s press release

In 2018, California became the first state to pass a commercial finance disclosure law (CDL) requiring certain commercial finance companies to make consumer-style disclosures to financing recipients. The CDL was the catalyst for the passage of similar laws in Utah, Virginia, and New York, and the introduction of commercial disclosure legislation in many other states

As we have repeatedly discussed this year in our Financial Services Perspectives blog, the current leadership of the CFPB has placed a significant emphasis upon fair lending. Seemingly once a month, or even more frequently at times, Director Rohit Chopra has announced a new initiative concerning fair lending and discrimination in the financial services industry.

On May 5, 2022, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (collectively the agencies) issued a joint notice of proposed rulemaking (the Proposed CRA Rule) that proposes changes to the way the agencies evaluate a bank’s performance under the

The Consumer Financial Protection Bureau (CFPB) issued a release on May 2, 2022, announcing the release of its Supervisory Highlights outlining identified consumer protection violations during the second half of 2021. In particular, the CFPB highlighted two industries of concern in its press release: auto servicers and credit reporting companies.

As for auto servicers, the

On Monday, the CFPB issued a press release announcing that it will start using its authority to examine non-bank financial services institutions that the CFPB has “reasonable cause to determine pose risks to consumers.” In addition, the CFPB has released a procedural rule designed to “increase transparency of the risk-determination process” by subjecting the results

The current leadership of the CFPB has not been shy about highlighting the importance of fair lending—and it is becoming increasingly clear that fair lending and equity within the financial services industry is one of the CFPB’s greatest priorities under Director Rohit Chopra. Just last month, the CFPB released a blog post to discuss possible

On February 16, 2022, legislators Blaine Luetkemeyer, French Hill, and Roger Williams submitted a letter to Consumer Financial Protection Bureau (CFPB) Director Rohit Chopra raising concerns regarding the Bureau’s Dodd Frank Act Section 1071 rulemaking.

As we have discussed, the CFPB issued its Section 1071 Notice of Proposed Rulemaking (NPRM) on September 1, 2021.

The Consumer Financial Protection Bureau (“CFPB”) issued a release on March 16, 2022 in order to announce changes to its supervisory operations with respect to discriminatory lending and servicing practices. 

In its press release, the CFPB explains that it has changed its approach towards examination of banks and non-banks in order to more closely “scrutinize”

In early February, the Federal Trade Commission (FTC) sent its annual letter to the Consumer Financial Protection Bureau (CFPB). The letter explained the FTC’s activities related to the Equal Credit Opportunity Act (ECOA) and Regulation B of ECOA. Pursuant to a January 2012 memorandum of understanding between the CFPB and the FTC, and consistent with