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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.

On January 13, a coalition of 39 state attorneys general — led by AGs from Pennsylvania, Washington, Illinois, Massachusetts, and California — reached a settlement with student loan servicer Navient over allegedly unfair, deceptive, and abusive student loan origination and servicing practices. The $1.8 billion settlement will undoubtedly draw eyes, but perhaps just as important

A recent settlement between the Federal Trade Commission (FTC) and a lead generator provides new insight into the FTC’s enforcement of sensitive personal data collection and sales under the Fair Credit Reporting Act (FCRA) and the agency’s Section 5(a) authority.

On January 5, the Federal Trade Commission (FTC) filed a complaint, alleging that ITMedia

On January 10, the Federal Trade Commission’s final rule, amending the Standards for Safeguarding Customer Information (Safeguards Rule) under the Gramm-Leach-Bliley Act (GLBA), became effective. We wrote about the final rule when it first published in October 2021 (see here). As a practical matter, the amendments will likely require many financial institutions to

On December 16, the Consumer Financial Protection Bureau (CFPB) issued orders to five companies offering buy now, pay later (BNPL) products. BNPL programs are designed to allow consumers to purchase goods and to defer payment over a short term with little to no interest, but with the potential for fees in the event of nonpayment.

On November 29, the Consumer Financial Protection Bureau (CFPB) settled a lawsuit by the National Association of Consumer Advocates (NACA) challenging the formation and operation of the Taskforce on Federal Consumer Financial Law (the Taskforce). The Taskforce was formed in October 2019 by then-CFPB Director Kathy Kraninger to examine the existing consumer financial services legal

On November 10, a group of Democratic senators sent a letter to Consumer Finance Protection Bureau (CFPB) Director Rohit Chopra, requesting that the CFPB take a proactive stance in its regulation of consumer reporting agencies (CRAs). The group, led by Sen. Brian Schatz (D-HI) and which includes Sens. Elizabeth Warren (D-MA) and Sherrod Brown (D-OH),

On November 29, House Financial Services Committee Chairwoman Maxine Waters (D-CA) and committee member Bill Foster (D-IL) sent a letter to the leaders of multiple federal regulators, asking them to monitor technological development in the financial services industry to ensure that algorithmic bias does not occur. The letter was sent to the following individuals:

  • Jerome

The Federal Trade Commission (FTC) recently released a “Serving Communities of Color” report that details fraud and consumer issues that have a disproportionately negative impact on communities of color. This report is the latest installment released by the FTC on the topic and follows prior initiatives, such as the 2014 “Every Community Initiative

On November 2, the House Financial Services Committee’s Task Force on Financial Technology held a hearing titled, “Buy Now, Pay More Later? Investigating Risks and Benefits of BNPL and Other Emerging Fintech Cash Flow Products.” For the hearing, the task force invited both consumer advocates and industry tradespeople to address several products, including buy now,

On October 18, consumer advocate groups and 19 state attorneys general wrote comment letters, urging banking regulators to denounce “rent-a-bank” arrangements between financial institutions and fintechs or other third-party providers.

The consumer advocates and attorneys general both push regulators to address and denounce financial institutions partnering with nonbanks to engage in high-cost lending otherwise prohibited