The CFPB recently published a blog post about the agency’s on-going efforts to monitor industry updates and innovation and how these changes align with regulatory obligations under the CFPB’s consumer protection laws. This post specifically highlighted using artificial intelligence (AI) and/or machine learning (ML) related to the adverse action notices that are required under the

On July 28, 2020, Troutman Pepper attorneys, Maryia Jones (Virginia Beach office) and Stephen J. Steinlight (New York – East Side office) will serve again on the faculty for their webinar series by Lorman Educational Services entitled, “Collection Disputes: A Good Defense Is the Best Offense.

The credit and collection industry remain under

The Federal Trade Commission (“FTC”) is holding its public workshop today on the proposed changes to the Gramm-Leach-Bliley Act of 1999’s Safeguards Rule (“Safeguards Rule”). For background, the Safeguards Rule requires financial institutions, and potentially affiliates and/or service providers, to keep customer information secure. The FTC has stated it seeks to modify the Safeguards Rule

The Consumer Financial Protection Bureau (CFPB) issued a final rule on July 7, 2020 rescinding the mandatory ability to repay underwriting provisions on small dollar loans that it had previously announced under 12 C.F.R. § 1041 (the Final Rule). The Final Rule has left the payments provisions intact.

The CFPB first finalized regulations governing small

The Supreme Court ruled yesterday that the Consumer Financial Protection Bureau (CFPB) can carry on, despite its unconstitutional leadership structure. The ruling gives the President the freedom to replace a CFPB Director at will. In a 5-4 decision, the Court held that the CFPB’s leadership by a single director removable only for cause was an

On June 18, the Consumer Financial Protection Bureau launched a pilot advisory opinion (“AO”) program in an effort to address some uncertainty in its existing regulations and make that process more public.

The program will allow entities to seek direct guidance on uncertainties they have with regulatory requirements that the CFPB oversees. The Bureau will

The Consumer Financial Protection Bureau issued a statement on June 3 relaxing the requirements for some electronic disclosures given for requests by consumers made via telephone for credit card plans. The CFPB acknowledged that credit card issuers are receiving more calls and may have limited staffing due to the pandemic. Many institutions are asking for

On June 16, 2020, the Consumer Financial Protection Bureau (“CFPB”) issued a seven-page FAQ memorandum addressing some of the most critical questions for compliance with the new consumer reporting requirements of the “CARES Act”. In sum, this Compliance Aid:

  • Addresses the specific credit reporting requirements of the CARES Act, including considerations for furnishers when

A New York franchise motor vehicle dealer agreed in May to pay $1.5 million to the Federal Trade Commission to settle charges that the dealership discriminated against African-American and Hispanic consumers and engaged in other unfair and deceptive practices.

In a complaint filed in the United States District Court for the Southern District of New

Authors:
Miranda Hooker, Partner, Pepper Hamilton
Ashley L. Taylor, Jr., Partner, Troutman Sanders
Ryan J. Strasser, Associate, Troutman Sanders
Katherine E. Stark, Associate, Pepper Hamilton

Throughout the 20th and 21st centuries, every national crisis in the United States has left a long wake of investigations in its trail at all levels of government.