Goodwin’s Consumer Finance Insights (CFI) monitors, reports, and analyzes the latest legal news, activity, and developments impacting the consumer finance industry. Consumer financial services companies—whether banks, fintechs, nonbank and alternative lenders, payment providers, or industry vendors or service providers, like digital advertisers and lead generators—face a constantly shifting and maturing regulatory and legal landscape. Growing from the Financial Crisis, today more than any time in history the consumer finance industry must confront a robust and growing body of industry legislation and regulation, all while under the microscope of sophisticated enforcers, like the Consumer Financial Protection Bureau (CFPB), Federal Trade Commission (FTC), and state regulators and attorneys general. It is critical for in-house and outside corporate counsel, compliance departments, and business executives to stay informed and aware of these developments to navigate institutional, reputational, and legal risks. Goodwin’s CFI is a singular source of the most recent industry news and latest enforcement activity for you to leverage. Here, you will find links to original enforcement documents, enforcement activity statistics, and reports, analysis, and commentary from Goodwin’s leading Consumer Financial Services Litigation and Enforcement practitioners.

CFBP and NY AG Sue Global Payment Company

On April 21, 2022, the Consumer Financial Protection Bureau (CFPB) anno​unced ​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…

Read More

CFPB Sues TransUnion and Senior Executive for Violating Law Enforcement Order Prohibiting Deceptive Marketing

On April 12, 2022, the Consumer Financial Protection Bureau (CFPB) announced that it had filed a lawsuit in federal court against TransUnion, two of its subsidiaries, and its longtime executive for failing to implement requirements of the CFPB’s 2017 law enforcement  order to TransUnion, and for violating Regulation V, which…

Read More

FTC Obtains Permanent Injunction Against For-Profit Medical School

FTC

On April 15, 2022, the Federal Trade Commission (FTC) announced that it obtained a permanent injunction against an Illinois-based, offshore, for-profit medical school for deceptive marketing practices. In its complaint ​and stipulated ​order​ filed same-day in the U.S. District Court for the Northern District of Illinois, the FTC alleged that the school violated the Telemarketing Sales Rule (TSR) when…

Read More

CFPB Proposes Rule to Assist Survivors of Human Trafficking in Obtaining Credit

On April 7, 2022, the Consumer Financial Protection Bureau (CFPB) announced it is proposing a rule that would assist survivors of human trafficking in achieving financial independence.  The proposed rule would aid survivors of human trafficking seeking to open bank accounts, access credit, and gain employment, by preventing credit reporting…

Read More

CFPB Files Lawsuit Against TransUnion for Deceptive Marketing

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…

Read More

Goodwin Webinar on CFPB Supervisory and Enforcement Priorities

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…

Read More

FTC Announces $10 Million Settlement With Auto Dealers for Alleged Junk Fees and Discriminatory Practices

On April 1, 2022, the Federal Trade Commission (FTC) announced that it reached a settlement​ with a group of Illinois-based auto dealers to resolve allegations that they had violated Sections 13(b) and 19 of the Federal Trade Commission Act (FTCA), 15 U.S.C. § 53(b), 57b, the Truth in Lending Act (TILA), 15 U.S.C. §§ 1601-1666j,…

Read More

CFPB Orders Student-Loan Servicer to Pay $1 Million Penalty and Remedy Miscommunications

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…

Read More

Court Enjoins Credit Repair Company From Making Misrepresentations to Consumers

On March 21, 2022, the Department of Justice (DOJ) announced that it obtained a permanent injunction against a credit repair company and its CEO, barring the company from making representations that it can improve consumers’ credit scores.  The injunction was issued by the United States District Court for the Southern District of Texas in relation…

Read More

FTC Stops Alleged Credit Repair Scheme that Filed False Identify Theft Complaints

FTC

On March 21, 2022, the Federal Trade Commission (FTC) announced that it had obtained an injunct​​ion halting a Texas-based credit repair operation.  The company allegedly obtained millions of dollars from consumers by falsely claiming to consumers the company could remove negative information from credit reports.  The company would then allegedly file fake identify theft reports to remove…

Read More

California DFPI Issues Guidance to Financial Institutions Regarding Russia Sanctions

On March 4, 2022, the California Department of Financial Protection and Innovation (DFPI) issued a reminder to its financial institution licensees regarding their obligations in light of the Russian invasion of Ukraine:  comply with U.S. sanctions on Russia, and employ safeguards to protect against attempts to use virtual currency transfers…

Read More

Credit Union Enters Into Consent Order with U.S. Attorney's Office Over Alleged SCRA Violations

On March 11, 2022, the U.S. Attorney’s Office (USAO) for the Eastern District of Virginia filed a consent order and settlement with a Virginia-based credit union for alleged violations of the Servicemembers Civil Relief Act (SCRA). The lawsuit, filed in U.S. District Court for the Eastern District of Virginia, alleged that the defendant unlawfully charged…

Read More

Goodwin's 2021 Consumer Financial Services Year In Review

Goodwin’s Consumer Financial Services Enforcement & Investigations and Litigation practices are once again proud to present our annual Consumer Finance Year In Review. Industry regulators staked out a clear intent to return to normal, rescinding pandemic-specific policies and letting go of relaxed enforcement. Reviewing the key developments and events in…

Read More

CFPB Issues Request for Information Regarding Junk Fees

On January 26, 2022, the Consumer Financial Protection Bureau (CFPB) issued a Request for Information Regarding Fees Imposed by Providers of Consumer Financial Products or Services (RFI).  In the RFI, the CFPB seeks public feedback regarding fees that are not subject to competitive pricing in order to assist the CFPB…

Read More

Massachusetts AG Settles Claims Against Subprime Auto Lender for $5.56 Million

On February 8, 2022,​ the Massachusetts Attorney General’s Office (Massachusetts AG) announced that it entered into a settlement agreement with a lender concerning its subprime auto loan disclosure and debt collection practices.  The Massachusetts AG filed an assurance of discontinuance​ in Suffolk County Superior Court alleging that the lender failed to provide consumers with adequate disclosures regarding how deficiencies…

Read More

DC AG Reaches $4 Million Settlement with Online Lender

On February 8, 2022, the Attorney General for the District of Columbia (DC AG) announced​ that a Delaware-based online lender has agreed to pay $3​.3 million to refund over 2,500 consumers who allegedly received misleadingly high-cost loans and lines of credit.  This agreement resolves​ a lawsuit filed by the DC AG in the Superior Court of the District of Columbia,…

Read More

CFPB Encourages Consumers To “Hold Accountable” Consumer Reporting Companies By Filing Disputes and FCRA Lawsuits

On January 27, 2022, the Consumer Financial Protection Bureau (CFPB) published its updated annual list of consumer reporting companies for the purpose of encouraging consumers to seek access to their files, and sue if they believe there is a Fair Credit Reporting Act (FCRA) violation.  The CFPB’s press release announcing the…

Read More