On July 19, 2023, the Consumer Financial Protection Bureau (“CFPB”) sued Snap Finance LLC, Snap R TO LLC, Snap Second Look LLC, Snap U.S. Holdings LLC, and Snap Finance Holdings LLC (collectively, the Snap Defendants or Snap). The complaint alleged that the Snap Defendants violated the: Consumer Financial Protection Act…
On May 31, 2023, the Consumer Financial Protection Bureau (CFPB) announced that it had entered into a consent order with an Indiana-based non-bank installment lender. The consent order alleges that the lender engaged in unfair, deceptive, and abusive acts or practices concerning the “marketing, sales, and financing of optional ancillary products” that it offered. Specifically, the…
On Monday May 10, 2023, the Consumer Financial Protection Bureau (CFPB or the Bureau) released a circular regarding the Bureau’s newest guidance that if a “financial institution unilaterally reopens [deposit] accounts to process debits or deposits, it can constitute an unfair practice under the [Consumer Financial Protection Act of 2012]…
On April 3, 2023, the Consumer Financial Protection Bureau (CFPB) issued a policy statement with guidance on what constitutes “abusive conduct” under the Consumer Financial Protection Act (CFPA). The CFPA, enacted in 2010 in response to the financial crisis, prohibits “abusive conduct” in consumer financial markets and identifies two categories…
On January 4, 2023, the Consumer Financial Protection Bureau (CFPB) and New York State Office of the Attorney General (NY AG) announced a joint enforcement action against one of the country’s largest publicly-traded indirect auto lenders. The 8-count complaint, filed in the United States District Court for the Southern District of New York,…
On December 22, 2022, the Consumer Financial Protection Bureau (CFPB) announced that it had reached a settlement with an international remittance company to resolve alleged violations of the Electronic Fund Transfer Act (EFTA), 15 U.S.C. § 1693 et seq., and its implementing Regulation E (Reg E), 12 C.F.R. Part 1005, Subpart B…
On December 20, 2022, the Consumer Financial Protection Bureau (CFPB) announced that it had entered into a consent order with a large national bank to resolve alleged violations of the Consumer Financial Protection Act’s (CFPA) prohibition of unfair, deceptive, and abusive acts or practices, 12 U.S.C. §§ 5531 and 5536. According to the…
On October, 4, 2022, the Consumer Financial Protection Bureau (CFPB) announced that it reached a settlement with a non-bank remittance transfer provider to resolve alleged violations of the Electronic Fund Transfer Act (EFTA), 15 U.S.C. § 1693 et seq., and its implementing Regulation E, 12 C.F.R. Part 1005, including Subpart B (known as the Remittance…
On August 16, 2022, the Pennsylvania Attorney General announced that a group of attorneys general for the Commonwealth of Pennsylvania, the States of New Jersey, Oregon, Utah, and Washington, and the District of Columbia (collectively, “the AGs”) had filed a multistate lawsuit against a personal lending company for allegedly charging consumers for “hidden add-on products” in violation of various…
On July 28, 2022, the Consumer Financial Protection Bureau (CFPB) announced that it had entered into a consent order with a large national bank to resolve alleged violations of the Truth in Lending Act (TILA), 15 U.S.C. § 1601 et seq., and its implementing regulation, Regulation Z (Reg Z), 12 C.F.R. part 1026; the Fair Credit…
On July 27, 2022, the Consumer Financial Protection Bureau (CFPB) and U.S. Department of Justice (DOJ) announced that they reached a settlement with a nonbank residential mortgage lender to resolve allegations of race-based lending discrimination in violation of the Fair Housing Act (FHA), 42 U.S.C. §§ 3601-3619; the Equal Credit Opportunity Act…
On July 26, 2022, the Consumer Financial Protection Bureau (CFPB) announced that it settled with a California-based auto lender who purchases and services retail installment contracts and vehicle leases for an affiliated automaker. The settlement resolves alleged violations of the Fair Credit Reporting Act (FCRA), 15 U.S.C. §§ 1681 et seq., and…
On May 23, 2022, the Consumer Financial Protection Bureau (CFPB) and the New York Attorney General (NY AG) announced that they have settled a case filed against six New York debt collection companies and affiliated individuals, resolving a one-and-a-half year enforcement action. The original complaint was filed on September 20, 2020 in the U.S. District Court for the Western…
On April 29, 2022, the Consumer Financial Protection Bureau (CFPB) announced that it reached a settlement with the CEO of a student loan debt relief company to resolve alleged violations of the Telemarketing Sales Rule (TSR), 16 C.F.R. Part 310, and the Consumer Financial Protection Act of 2010 (CFPA), 12 U.S.C. §§ 5531(a),…
On April 21, 2022, the Consumer Financial Protection Bureau (CFPB) announced a joint enforcement action with the New York Attorney General (NY AG) against one of the largest international remittance providers in the United States. The seven-count complaint, filed in U.S. District Court for the Southern District of New York, challenges the Dallas-based company’s remittance…
On April 12, 2022, the Consumer Financial Protection Bureau (CFPB) announced that it filed a lawsuit against TransUnion and the company’s former executive. The complaint, filed in the U.S. District Court for the Northern District of Illinois, alleges that TransUnion violated a 2017 CFPB consent order which resolved allegations that the company deceptively marketed credit scores…
On April 5th, Goodwin attorneys hosted a webinar discussing the Consumer Financial Protection Bureau’s (CFPB) changes to its supervisory and enforcement priorities with respect to unfair, deceptive, or abusive acts or practices (UDAAPs) under the Consumer Financial Protection Act (CFPA). To recap what was discussed: Download our presentation materials. Watch…
On March 30, 2022, the Consumer Financial Protection Bureau (CFPB) announced that it entered into a consent order with a student-loan servicer for alleged deceptive acts and practices in violation of the CFPA, 12 U.S.C. §§ 5531(a), 5536(a)(1)(B). The CFPB alleged that the servicer made deceptive statements to student loan borrowers and misrepresented their…
On January 18, the Consumer Financial Protection Bureau (CFPB) announced that it had agreed to a settlement with a payment processing company, resolving allegations that the company assisted third parties in profiting from fraudulent services and products. The proposed stipulated judgment, if entered by the court, will resolve allegations that the company was processing…
On January 10, the Consumer Financial Protection Bureau (CFPB) announced that it filed a complaint against three New York-based debt collection companies and their owners. The CFPB alleged the companies sold debts to collection companies that used unlawful collection tactics. Specifically, the CFPB alleged the companies knew or should have known that the…