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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 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

Beginning next year, New Mexico will join a handful of other states (including, among others, California, Illinois, and Colorado) setting stringent interest rate caps on consumer loans. House Bill 132, which Gov. Michelle Lujan Grisham signed on March 1, 2022, will slash the annual percentage rate (APR) applicable to loans made under New Mexico’s

CFPB Warns of Serious Issues with Fair Lending Standards for AppraisersThe Consumer Financial Protection Bureau (“CFPB”) released a blog post on February 4 warning of the possibility of discrimination in the appraisal process. The CFPB explained that, although appraisal discrimination based on racial inequalities has been outlawed for more than 50 years, they are still seeing reports of biased appraisers who “base their value judgments

CFPB Fall Supervisory Highlights Shed Light on Agency Priorities – Fair LendingAs 2021 came to an end, the Consumer Financial Protection Bureau (CFPB) released its 2021 Fall Supervisory Highlights, which cover the CFPB’s findings of examinations completed on the first half of the year. Though the CFPB’s Fair Lending Supervision Program reviews compliance with the Equal Credit Opportunity Act (ECOA) and its implementing regulation, Regulation B,

The COVID-19 pandemic has been a focal point for the Consumer Financial Protection Bureau (CFPB) – especially with regard to mortgage servicers and loss mitigation programs. In its Fall Supervisory Highlights, the CFPB noted the increase in borrowers needing loss mitigation assistance in light of the COVID-19 pandemic, and cited mortgage servicers for two

CFPB Fall Supervisory Highlights Shed Light on Agency PrioritiesYesterday, the Consumer Financial Protection Bureau (CFPB) released its Fall Supervisory Highlights. The report covers examinations completed between January and June of 2021. Over the last year, the Biden-era CFPB has made various statements about its priorities. For instance, the Bureau has issued comments or taken action related to the small dollar lending agenda,