Consumer Financial Services Law Blog
Dykema Gossett PLLC
Dykema Gossett PLLC

Consumer Financial Services Law Blog

Consumer Financial Services Law Blog

News and analysis regarding Consumer Financial Services litigation and regulation, and activities of the Consumer Financial Protection Bureau


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Showing 30 posts in CFPB Enforcement Actions.

CFPB Consent Order Holds Import for Supervised Entities Using Third-Party Vendors

The Consumer Protection Financial Bureau (“CFPB”) announced on October 29, 2015, that it took action against two of the largest employment background screening report providers, General Information Services (“GIS”) and its affiliate e-Background-checks.com, Inc. (“e-Background-checks.com”) for alleged violations of the Fair Credit Reporting Act. The press release also linked a Consent Order, by which GIS and e-Background-checks.com agreed to pay a $2.5 million penalty and provide $10.5 million to affected consumers, among other sanctions. Read More ›

CFPB Reflects on Five Years of Dodd-Frank Enforcement in Written Senate Testimony

On July 15, 2015, the Consumer Financial Protection Bureau (“CFPB”) published on its website the written testimony of CFPB Director Richard Cordray before the Senate Committee on Banking, Housing, and Urban Affairs. In his testimony, Mr. Cordray noted that “[n]ext week marks five years since the passage of the Dodd-Frank Wall Street Reform and Consumer Protection Act and four years since the [CFPB] opened its doors.” Read More ›

No Formal Grace Period for TILA-RESPA Integrated Disclosure Rule (TRID) – August 1 Implementation Effective Date Still Stands

UPDATE: On Wednesday, June 17, CFPB Director Richard Cordray issued a statement on a proposed amendment to the Truth in Lending and Real Estate Settlement Procedures Act Integrated Disclosure Rule (TRID). Citing an administrative error that violated federal law and would delay the operative date of the rule by two weeks, the amendment proposes to delay the enforcement of the rule until October 1, 2015. Read More ›

Lesson Learned from CFPB’s Actions against Banks Engaging in Illegal Marketing Services Kickback Scheme

Under Section 8 of the Real Estate Settlement procedures Act (RESPA), it is illegal for anyone to give or receive a fee, kickback or anything of value in exchange for referrals of settlement service business to a particular person or organization relating to a federal mortgage loan. Violations of this section of RESPA are subject to civil and criminal penalties which could be assessed in the form of a fine, imprisonment or both. Read More ›

In Support of Revisions to Military Lending Act Rules, CFPB Issues Report on Current Practices and Outcomes

On December 29, 2014, the Consumer Financial Protection Bureau (CFPB) issued a report on the implications of certain loopholes in the current Military Lending Act rules.  The CFPB is “urging the Department of Defense to finalize” its proposed revisions to these rule.  The revisions promise to expand the scope of the rules and to close many of the most significant loopholes, subjecting lenders to additional regulatory and litigation risk. Read More ›

CFPB Reports On Credit Card Marketing To College Students

The pitch is familiar to almost everyone who has attended college: “Free pizza! Just sign up for a credit card with Bank!” or “No strings attached! Free T-shirt when you register with Bank!” Unfortunately, for many students these gimmicks lead to out of control spending and an early brush with systematic debt. On December 15, 2014, the Consumer Financial Protection Bureau (CFPB) issued its yearly report analyzing the agreements financial institutions make with colleges to market credit cards to students. Read More ›

CFPB Announces Proposed No-Action Letter Program

On October 10, 2014, the Consumer Financial Protection Bureau (CFPB) announced a proposed policy under which they would issue No-Action Letters to applicants indicating that the CFPB would not initiate supervisory or enforcement action regarding innovative financial products or services.  Under this proposal, the CFPB would issue these No-Action Letters when a new financial product or service promises "substantial customer benefit where there is substantial uncertainty whether or how specific provisions of statutes or regulations implemented by the [CFPB] would be applied." Read More ›

CFPB Warns Credit Card Companies About Deceptive Marketing - Again

The Consumer Financial Protection Bureau (CFPB) has issued a new warning to credit card companies in order to curb recent deceptive marketing practices.  This is not the first time that the CFPB has warned credit card companies to be more clear with their offerings to consumers.  Read More ›

CFPB Targets For-Profit Corinthian Colleges for Alleged Predatory Lending

On September 16, 2014, the Consumer Financial Protection Bureau (CFPB) announced that it had filed a lawsuit against Corinthian Colleges (Corinthian), which operates nearly 100 for-profit colleges under the names Heald, Everest, and WyoTech.  The CFPB charges Corinthian with predatory lending and alleges that Corinthian inflated tuition costs, misrepresented students’ career prospects, and engaged in aggressive and embarrassing debt collection tactics, even while students were still enrolled in school. The Complaint outlines in detail Corinthian’s alleged internal policies of targeting individuals with “low self-esteem,” who are “isolated,” and have “minimal to non-existent understanding of basic financial concepts.”  Read More ›

Interagency Guidance Regarding Unfair or Deceptive Credit Practices

Several regulatory agencies have jointly issued guidance to banks, saving associations, and Federal credit unions concerning the repeal of consumer protection regulations promulgated under the FTC Act.  The Board of Governors of the Federal Reserve System (the Board), the Consumer Financial Protection Bureau (CFPB), the National Credit Union Administration (NCUA), and the Office of the Comptroller of Currency (the OCC) jointly issued guidance on August 22, 2014 to banks, savings associations, and Federal credit unions explaining that the repeal of certain regulations as a result of the Dodd-Frank Act should not be construed as a tacit approval of these prohibited practices addressed in the regulations, and that the CFPB may still enforce such rules in principal under its general mandate to prohibit deceptive practices.  Read More ›