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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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In this episode, Brooke Conkle and Chris Capurso delve into the topic of refinancing and its impacts on the auto finance industry. They are joined by special guest Jason Cover, who provides insights and education on retail installment contracts, loans, and the impact of refinancing programs. Jason, a partner in the firm’s Philadelphia office, routinely counsels providers of consumer financial services, including banks, licensed lenders, and fintech providers, on regulatory compliance matters and government supervisory and enforcement matters. He also regularly offers guidance on electronic payments and payment network rules; electronic contracting and mobile commerce; UDAAP statutes prohibiting unfair, deceptive, and abusive acts and practices; and the CFPB’s Rule on Payday, Vehicle Title, and Certain High-Cost installment Loans (Payday Rule).

On August 7, the U.S. Department of Treasury hosted a virtual briefing to discuss the steps that the Biden-Harris administration is taking to address perceived unfair and deceptive practices in the consumer solar energy industry. Deputy Secretary of Treasury Wally Adeyemo, along with Federal Trade Commission (FTC) Chair Lina Khan and Consumer Financial Protection Bureau (CFPB) Director Rohit Chopra, announced a new interagency consumer solar industry initiative directed at both sales and financing of residential systems. Each made statements about the unique effort to root out anti-competitive and sometimes-fraudulent activity by a handful of “bad actors” who are taking advantage of the burgeoning industry. The presenters also noted that they will be coordinating with state attorneys general (AG) and state financial regulators.

In this episode of Moving the Metal, Troutman Pepper attorneys Brooke Conkle and Chris Capurso discuss the Consumer Financial Protection Bureau’s (CFPB) new report on negative equity in auto lending. This report, the first of its kind, utilizes data from the CFPB’s 2023 Auto Finance Data Pilot, which was issued to major banks, finance companies, and captive lenders. Brooke and Chris analyze the impact of the report, including what the report may indicate for the bureau’s upcoming priorities.

In this inaugural episode of Moving the Metal, Troutman Pepper attorneys Brooke Conkle and Chris Capurso examine the major requirements of the FTC’s proposed CARS Rule. After a refresher on the rule’s requirements, Brooke and Chris discuss the current status of the litigation surrounding the rule, including a discussion of the briefs and data submitted by the FTC and the trade groups fighting the rule. Tune in as Brooke and Chris look under the hood to examine the FTC’s fine print and where the rule currently stands in the courts, helping your auto finance company avoid regulatory pitfalls.

On July 2, the Consumer Financial Protection Bureau (CFPB or Bureau) published the summer edition of its Supervisory Highlights, focusing on examinations of auto and student loan servicing companies and debt collectors that were completed between April 1, 2023 and December 31, 2023. The report also highlights consumer complaints about medical payment products and identifies concerns with financial institutions freezing deposit accounts.

In this special episode, Brooke Conkle and Chris Capurso discuss a recently released circular from the Consumer Financial Protection Bureau (CFPB). They are joined by special guest Caleb Rosenberg, who provides insights into the potential impacts this “quietly released” circular may have on the auto finance industry. Caleb brings a wealth of experience, including assisting businesses with secured and unsecured loan agreements, retail installment sales contracts, credit card agreements, and alternative finance agreements. He also helps clients navigate regulatory inquiries, particularly those concerning the application of state law to alternative financing products. While this marks the final episode of our five-part series on auto finance issues, stay tuned for more content. Be sure to listen until the end for a BIG announcement!

Today, the Consumer Financial Protection Bureau (CFPB or Bureau) released a report on the state of negative equity in auto lending. The CFPB says it found that financing negative equity creates increased risks for consumers, and states that the CFPB will be putting negative equity under scrutiny.

Today, the Consumer Financial Protection Bureau (CFPB) announced that its so-called “Payday, Vehicle Title and Certain High-Cost Installment Loans” rule (Rule) will go into effect on March 30, 2025. While ostensibly aimed at higher-APR lending (e.g., loans with an APR above 36%), it also applies to most creditors, including banks, offering loans: (1) that are substantially repayable within 45 days or less; or (2) that have a bullet or balloon payment feature. It applies by its plain terms to a number of mainstream financial products and products marketed to high-net worth individuals, none of which the CFPB seems to have considered when promulgating the rule.

On May 28, the Federal Trade Commission (FTC) released its annual report to the Consumer Financial Protection Bureau (CFPB) detailing enforcement and educational activities undertaken in 2023. The report pertains to actions under the Truth in Lending Act (TILA) and Regulation Z, the Consumer Leasing Act (CLA) and Regulation M, and the Electronic Fund Transfer Act (EFTA) and Regulation E. Specifically, the report highlights FTC initiatives in areas such as automobile financing and leasing, electronic fund transfers, so-called junk fees, payday lending, and negative options.

The Consumer Financial Protection Bureau (CFPB or Bureau) has issued a circular warning covered persons that including unlawful or unenforceable terms and conditions in consumer contracts can violate the prohibition on deceptive acts or practices in the Consumer Financial Protection Act (CFPA).