Join us for the third episode in a special three-part series covering the CFPB’s intention to propose new rules under the Fair Credit Reporting Act (FCRA). In this episode, Troutman Pepper Partners Chris Willis, Dave Gettings, Kim Phan, Ethan Ostroff, and Ron Raether discuss the potential implications of regulating data brokers under the FCRA, and how this might affect data brokers as well as other types of entities, including users, consumer reporting agencies, and resellers.
When using artificial intelligence (AI) or complex credit models, can lenders rely on the checklist of reasons provided in Regulation B sample forms for adverse action notices? According to today’s guidance issued by the Consumer Financial Protection Bureau (CFPB or Bureau), the answer to that question is, in many circumstances, no.
The Consumer Financial Protection Bureau (CFPB) has issued a final rule adjusting the Truth in Lending Act (TILA) dollar amounts for certain provisions, including under the Home Ownership and Equity Protection Act of 1994 (HOEPA), and the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), where appropriate, based on the annual percentage change reflected in the consumer price index (CPI). The rule takes effect on January 1, 2024.
To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Finance Services industry over the past week:
On September 7, the U.S. District Court for the Eastern District of Michigan granted summary judgment in the defendant’s favor finding that the plaintiff had not suffered a concrete injury and therefore lacked standing to assert a claim under the Fair Debt Collections Practices Act (FDCPA).
Join us for the second episode in a special three-part series covering the CFPB’s intention to propose new rules under the Fair Credit Reporting Act (FCRA). In this episode, Troutman Pepper Partners Chris Willis, Dave Gettings, Kim Phan, Ron Raether, and Ethan Ostroff discuss the regulation of credit header data and the potential impact on
Join us for the second episode in a special three-part series covering the CFPB’s intention to propose new rules under the Fair Credit Reporting Act (FCRA). In this episode, Troutman Pepper Partners Chris Willis, Dave Gettings, Kim Phan, Ron Raether, and Ethan Ostroff discuss the regulation of credit header data and the potential impact on the FCRA and consumer reporting agencies, as well as users and data brokers.
On September 7, the Consumer Financial Protection Bureau (CFPB) released an issue spotlight focusing on the role that mobile device operating systems play in determining consumer’s payment options. According to the CFPB, “[g]iven the continued shift toward the use of contactless payments on mobile devices like smartphones and wearables, there is now readily available technology for consumers to securely make [point-of-sale (POS)] payments through different apps and services … Any restrictions imposed by the dominant operating systems … will have an outsized effect on access to payments systems and may hinder the development of a truly open ecosystem.”
To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Finance Services industry over the past week:
The Seventh Circuit Court of Appeals recently affirmed a district court’s dismissal of a suit holding that the plaintiff had not suffered a concrete injury, and therefore, lacked standing to assert a claim under the Fair Debt Collections Practices Act (FDCPA).