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

The Consumer Financial Protection Bureau’s (CFPB) focus on ensuring loan servicers’ compliance with the implementation of the Public Service Loan Forgiveness (PSLF) program continues. On March 30, 2022, the CFPB entered into a Consent Order with student loan servicer EdFinancial Services, LLC, to settle the CFPB’s allegations that EdFinancial committed deceptive servicing acts and practices

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 Priorities – Small Dollar LendingThe Fall Supervisory Highlights came out this month and reports the Bureau’s findings of examinations completed between January 2021 and June 2021. The CFPB publishes the Supervisory Highlights to help institutions better understand how the CFPB examines and monitors compliance with federal consumer financial laws. CFPB examiners often find problems during supervisory examinations that are

CFPB Auto Finance Consent Order: A Sign of Things to Come for Add-On Products?On May 21, 2021, the Consumer Financial Protection Bureau (CFPB) and 3rd Generation, Inc. d/b/a California Auto Finance entered into a Consent Order in which the CFPB alleged unfair acts or practices in connection with an auto finance add-on product.

What was the add-on product?

According to the Consent Order, 3rd Generation purchases and services

The Enforcement Blitz Continues: CFPB Signals Return to Aggressive Enforcement of Vague UDAAP RestrictionsCFPB Acting Director David Uejio wasted no time in signifying the changes to come under the Biden administration. Last week, the CFPB rescinded its January 2020 “Statement of Policy Regarding Prohibition on Abusive Acts or Practices” (2020 Policy), which provided the financial services industry a much-welcomed reprieve from enforcement actions for unfair, deceptive,

FTC and NY AG Target Merchant Cash Advance CompaniesOn June 10, 2020, the Federal Trade Commission and the  New York Office of the Attorney General filed actions against two merchant cash advance (MCA) companies – RCG Advances and Ram Capital Funding – and individuals associated with both companies in the Southern District of New York and the Supreme Court of the State of

Think Finance Settlement: Final Resolution Leaves More Questions than It Answers as to Future of CFPB EnforcementThe CFPB announced that it settled with Think Finance, LLC and six subsidiaries on February 5. The settlement follows protracted litigation beginning in November 2017 involving the CFPB’s allegations that Think Finance “engaged in unfair, deceptive, and abusive acts and practices in violation of the Consumer Financial Protection Act in connection with the illegal collection

In 2010, Congress amended the Electronic Funds Transfer Act (EFTA) by creating “a comprehensive system of consumer protections for money sent by U.S. consumers to individuals and businesses in foreign countries.” In 2013, the CFPB issued the Remittance Transfer Rule to implement the EFTA’s new requirements and updated its EFTA exam procedures to incorporate the

Last November, Bradley’s Financial Services Perspectives team predicted that the Consumer Financial Protection Bureau’s (CFPB) then upcoming Notice of Proposed Rulemaking (NPRM) for the Does the New Debt Collection Rule Apply to First-Party Creditors? Fair Debt Collection Practices Act (FDCPA) might cause concern for first-party creditors. By way of background, the statutory scope of the FDCPA does not reach first-party creditors, instead applying only to