Last month, the Consumer Financial Protection Bureau (CFPB) issued orders to five companies offering buy now, pay later (BNPL) products, asking them to provide information on several topics, including:

  • Business models,
  • BNPL performance metrics,
  • Disclosures and other consumer protections,
  • User demographics, and
  • Data harvesting and monetization.

For more information the CFPB’s inquiry, please see our

In Almada v. Krieger, No. 21-55275 (9th Cir. Jan. 24, 2022), the Ninth Circuit partially reversed a decision by the U.S. District Court for the Southern District of California, granting summary judgment in favor of a debt collector in a Fair Debt Collections Practices Act (FDCPA) case. In doing so, it held that

Like most industries today, Consumer Finance Services businesses are being significantly impacted by the novel coronavirus (COVID-19). Troutman Pepper has developed a dedicated COVID-19 Resource Center to guide clients through this unprecedented global health challenge. We regularly update this site with COVID-19 news and developments, recommendations from leading health organizations, and tools that businesses can

On December 8, District of Columbia Attorney General Karl A. Racine transmitted the “Stop Discrimination by Algorithms Act of 2021 (Act)” for consideration and enactment by the Council of the District of Columbia. While discrimination of various types is prohibited by a variety of federal and D.C. laws, this bill would apply to a

On January 25, the Florida Office of Financial Regulation (OFR) issued an investor advisory “to raise awareness about decentralized finance (DeFi), a relatively new blockchain-based group of financial services gaining popularity[.]” The OFR defines DeFi as “financial services provided by an algorithm on a blockchain, without a traditional financial services company.” The advisory describes DeFi,

On January 25, the House Committee on Financial Services announced its hearing schedule for the month of February, which includes a full committee hearing on February 8 at 10:00 a.m. ET on “Digital Assets and the Future of Finance: The President’s Working Group on Financial Markets’ Report on Stablecoins.”

As previously discussed by our colleagues,

Indiana Attorney General Todd Rokita started 2022 by announcing his intention to continue aggressively pursuing robocallers and summarizing the actions taken by his office in 2021. This included calling on the Federal Communications Commission (FCC) to revise its rules to increase accountability, implementing new technologies to shorten the time for the AG to investigate complaints

On November 1, the President’s Working Group on Financial Markets (PWG), along with the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency, issued a “Report on Stablecoins” (Report) that provided background on stablecoins, identified regulatory gaps related to such digital assets, and offered recommendations for addressing those gaps. After outlining

Like most industries today, Consumer Finance Services businesses are being significantly impacted by the novel coronavirus (COVID-19). Troutman Pepper has developed a dedicated COVID-19 Resource Center to guide clients through this unprecedented global health challenge. We regularly update this site with COVID-19 news and developments, recommendations from leading health organizations, and tools that businesses can

On January 20, the Federal Trade Commission (FTC) issued an advisory opinion on the impact of the Trade Regulation Rule Concerning Preservation of Consumers’ Claims and Defenses (Holder Rule) on the recovery of attorneys’ fees and costs above the amount paid on a consumer receivable arising out of a financed sale of goods or services.