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Chris Capurso

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Chris focuses his practice on consumer financial services compliance, guiding clients through the many federal and state laws and regulations that impact consumer credit programs.

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Please join Consumer Financial Services Partner Ethan Ostroff and his guests and colleagues Alan Wingfield, Chris Capurso, and Derek Schwahn in the third episode of a special four-part series on recent developments with the Consumer Financial Protection Bureau (CFPB). In this episode, topics include:

  • The CFPB’s recent focus on the furnishers’ obligation to respond to consumer disputes;
  • Steps furnishers can take to ensure they properly investigate and respond to consumer disputes;
  • Recent developments on reporting medical debt; and
  • The CFPB’s views on what should and should not be contained on a consumer’s credit report.

As we previously posted here, in March, Utah enacted its Commercial Financing Registration and Disclosure Act (CFRDA), requiring commercial financing providers to register with the Utah Department of Financial Institutions (DFI). The process requires registering with the Nationwide Multistate Licensing System and Registry (NMLS), providing certain information about the provider, and disclosing information about…

As we previously posted here, in March, Utah enacted its Commercial Financing Registration and Disclosure Act (CFRDA), requiring commercial financing providers to register with the Utah Department of Financial Institutions (DFI). The process requires registering with the Nationwide Multistate Licensing System and Registry (NMLS), providing certain information about the provider, and disclosing information about…

As we previously posted on June 23, the Federal Trade Commission (FTC or Commission) released a proposed Motor Vehicle Dealers Trade Regulation Rule. This new rule could allow the FTC to regulate dealers exempt from the Consumer Financial Protection Bureau’s (CFPB) jurisdiction under Section 1029(a) of the Dodd-Frank Act and would impose significant limits on…

Bankers are gearing up to oppose an effort by the Consumer Financial Protection Bureau (CFPB or Bureau) to prevent an increase in allowable late charges for credit cards. In letters dated August 1, the American Bankers Association, Consumer Bankers Association, Credit Union National Association, and National Association of Federally‐Insured Credit Unions (Associations), as well…

On March 1, the Consumer Financial Protection Bureau (CFPB) released a report highlighting the effect of medical collections on consumer credit reports. The CFPB found that medical collections tradelines appeared on 43 million credit reports, and past-due medical debt is more prevalent among Black and Hispanic individuals. That same month, the three nationwide consumer reporting…

On July 15, the California Department of Financial Protection and Innovation (DFPI) issued an invitation for comments on proposed additions to regulations implementing the Debt Collection Licensing Act (DCLA). According to the invitation, the new provisions pertain “to the scope, annual report, and document retention requirements of the DCLA.” For example, the proposed regulations define…

On July 13, the FTC published its proposed Motor Vehicle Dealers Trade Regulation Rule in the Federal Register. As we covered here, the proposed rule would create a host of new compliance challenges for motor vehicle dealers, including a new national standard for price advertising, trigger disclosures for payments, added paperwork for the…

The Consumer Financial Protection Bureau (CFPB or Bureau) agreed to a March 31, 2023 deadline to issue a final rule under Section 1071 of Dodd-Frank. Section 1071 amended the Equal Credit Opportunity Act (ECOA) to impose significant data collection requirements on small business creditors. The CFPB accepted the deadline as part of a previously agreed litigation settlement regarding alleged delays in the rulemaking process. The court accepted the deadline and maintained jurisdiction over the matter to oversee compliance with the settlement and to address any potential requests for modification.

When the Consumer Financial Protection Bureau (CFPB or Bureau) unveiled its UDAAP exam manual at the end of March 2022, announcing that it had decided to interpret the word “unfair” in Dodd-Frank to prohibit discrimination, even where specific statutes like the Equal Credit Opportunity Act do not apply, we expressed skepticism about the viability of…