On June 4, 2024, the CFPB released a circular cautioning companies against including unlawful or unenforceable terms and conditions in contracts for consumer financial products or services. The circular asserts
Continue Reading CFPB Warns Against Deceptive Fine-Print Tactics Targeting ConsumersMatthew White
Matt White guides clients through regulatory compliance challenges and represents clients in regulatory and civil investigations and litigation.
Matt has counseled fintech and payment companies on regulatory compliance matters, including those involving the Electronic Fund Transfer Act, the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, the Truth in Lending Act, and their respective implementing regulations (Regulations E, V, P, and Z). Adept with the Consumer Financial Protection Bureau’s (CFPB) Prepaid Rule, Matt has provided guidance regarding prepaid cards and related compliance.
Matt has also aided clients in developing regulatory compliant products and functionalities, including an earned wage access program, reimbursement prepaid card programs, new merchant cash advance products, and tokenized payment capabilities. In connection with products on which Matt advises, he has also negotiated high-stakes technology sales agreements involving complex regulatory issues, including compliance with data privacy laws, financial regulations, and card network rules.
Beyond helping clients strategize for regulatory complexity, Matt also helps clients navigate government investigations and enforcement actions brought by the Federal Trade Commission (FTC), CFPB, and state attorneys general.
CFPB Launches Public Inquiry into Rising Mortgage Closing Costs and ‘Junk Fees’
On May 30, 2024, the CFPB issued a new request for information (RFI) from the public regarding “why closing costs are increasing, who is benefiting, and how costs for borrowers…
Continue Reading CFPB Launches Public Inquiry into Rising Mortgage Closing Costs and ‘Junk Fees’FTC Takes Action Against Doxo, Citing Junk Fees
The FTC recently took action against bill payment company Doxo and its co-founders, accusing them of engaging in deceptive “junk fee” practices that harmed consumers. The FTC’s complaint alleges that Doxo used misleading search ads and deceptive designs to conceal millions of dollars in “junk fees.”…
Continue Reading FTC Takes Action Against Doxo, Citing Junk Fees
California AG Publishes FAQs on California’s ‘Junk Fee’ Law
On May 8, 2024, the California Attorney General released a list of frequently asked questions (FAQs) to help businesses comply with SB 478, California’s soon-to-be effective “Hidden Fees Statute,”…
Continue Reading California AG Publishes FAQs on California’s ‘Junk Fee’ LawCFPB Releases Report Highlighting Junk Fees in Mortgage Servicing
On April 24, 2024, the CFPB unveiled its latest edition of Supervisory Highlights, shedding light on its ongoing battle against what it deems as “junk fees” imposed by mortgage servicers.
Continue Reading CFPB Releases Report Highlighting Junk Fees in Mortgage Servicing
CFPB Announces New Compliance Deadlines for Small Business Lending Rule
On May 17, 2024, the CFPB announced it will issue an interim final rule to extend the compliance deadlines for its Small Business Lending Rule. When it takes effect, the…
Continue Reading CFPB Announces New Compliance Deadlines for Small Business Lending RuleSupreme Court Holds That CFPB’s Funding Is Constitutional, Clearing Way for Rulemaking Agenda
On May 16, 2024, the U.S. Supreme Court held 7-2 in Consumer Financial Protection Bureau v. Community Financial Services Association of America (CFSA) (Docket No. 22-448) that the CFPB’s funding…
Continue Reading Supreme Court Holds That CFPB’s Funding Is Constitutional, Clearing Way for Rulemaking AgendaCFPB Releases Report Highlighting Financial and Privacy Risks in Online Video Gaming Marketplaces
On April 4, 2024, the CFPB issued a report titled “Banking in Video Games and Virtual Worlds” that examines the financial and privacy risks to consumers in online video gaming…
Continue Reading CFPB Releases Report Highlighting Financial and Privacy Risks in Online Video Gaming MarketplacesCFPB Streamlines Nonbank Supervisory Designation Procedures
On April 16, 2024, the CFPB issued a revised rule aimed at streamlining its procedures for designating nonbank covered entities for supervision. The CFPB said the revised procedures “reflect changes…
Continue Reading CFPB Streamlines Nonbank Supervisory Designation ProceduresCalifornia Proposes Revisions to Autorenewal Law
On April 1, 2024, California’s legislature introduced Assembly Bill 2863, which proposes amendments to California’s Automatic Renewal Law. If enacted, the proposed amendments would introduce stricter mandates for disclosures, consent, and cancellation processes and further align California’s ARL with the FTC’s proposed changes to its Negative Option Rule.
Continue Reading California Proposes Revisions to Autorenewal Law