The Consumer Financial Protection Bureau (CFPB) recently issued its final rule to implement Section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The rule amends the Equal Credit Opportunity Act (ECOA), introducing substantial data collection and reporting requirements for small business lenders and finance companies. In this blog post, we delve deeper

Less than three years after the U.S. Supreme Court reviewed the CFPB’s appointment structure, the bureau again finds itself before the Court in what could prove the most consequential case for the financial services industry in years. Four months ago, the Fifth Circuit Court of Appeals issued a decision in Community Financial Services Association of

In light of growing concerns, the Federal Financial Institutions Examination Council (FFIEC) Appraisal Subcommittee (ASC) held its first hearing on appraisal bias on January 24, 2023, at the Consumer Financial Protection Bureau (CFPB) headquarters. The FFIEC, a federal interagency body comprised of the Board of Governs of the Federal Reserve System (FRB), Federal Deposit Insurance

On January 18, 2023, the Consumer Financial Protection Bureau (CFPB) released an updated version of its Mortgage Servicing Examination Manual. As the CFPB described in a corresponding blog post, the manual outlines “the types of information that CFPB examiners gather to evaluate mortgage servicers’ policies and procedures; assess whether servicers are complying with

The Consumer Financial Protection Bureau (CFPB) released a report (2022 CFPB Report) on January 3, 2023, detailing information and trends related to how nationwide consumer reporting agencies (NCRAs) responded to consumer complaints from October 2021 to September 2022.

Under Section 611(e)(3) of the Fair Credit Reporting Act (FCRA), NCRAs, including Equifax, Experian, and TransUnion, are

The Consumer Financial Protection Bureau (CFPB) issued a release on December 12, 2022, considering a proposed rule that would require nonbank financial institutions to register with the CFPB following a confirmed violation of consumer protection laws.

This proposed rule notably seeks not only registration, but also reporting by nonbank institutions, each time they are subject

As we all hit the grocery store for that forgotten cranberry sauce and send a few last urgent work emails, we hope everyone is able to be with friends and family this Thanksgiving. Here at Bradley, we are counting our blessings and looking back at another remarkable year. We are thankful for being able to

On October 19, 2022, the Fifth Circuit Court of Appeals issued its opinion in Community Financial Services Association of America, et al. v. CFPB (CFSA v. CFPB) invalidating the CFPB’s Payday, Vehicle-Title, and Certain High-Cost Installment Loans rule (Small-Dollar Rule). The three-member panel decision calls into question the future viability of the CFPB

The Consumer Financial Protect Bureau (CFPB) issued a release on September 15, 2022, announcing its intent to issue additional interpretive guidance or rules to ensure “Buy Now, Pay Later” (BNPL) lenders comply with the same or similar regulations already established for credit cards following a study on the industry.

In its press release, the CFPB

On Thursday, September 22, 2022, the Consumer Financial Protection Bureau (CFPB) issued a new request for information (RFI) regarding mortgage servicing, potentially opening the door for much-needed regulatory reforms. The RFI is focused on inquiries regarding refinances and, more generally, ways to streamline short and long-term loss mitigation options. It includes 37 specific requests, allowing