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Gil Rudolph

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Gil Rudolph focuses his practice on the representation of finance companies, banks, mortgage originators and servicers, lease company transactions, retail installment transaction financers and other consumer financial service providers in regulatory and litigation matters. Gil also represents various alternative financial service providers, including small dollar/short term lenders, check cashers, pawn and auto title lenders. He additionally represents various participants in the credit, debit, and prepaid card issuance and processing industries.

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In its continued focus on so-called illegal “junk fees,” the CFPB issued an Advisory Opinion on the obligations of large banks and credit unions. The CFPB’s actions arise at a…

Continue Reading CFPB Issues Advisory Opinion on ‘Illegal Junk Fees’ By Large Financial Firms

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  • CFPB proposes rule requiring nonbanks to “register” with the CFPB if they include certain terms and conditions in their form contracts, including in their website terms of use
… Continue Reading CFPB Says ‘Show Me The (Consumer Unfriendly) Fine Print’

The Consumer Financial Protection Bureau (CFPB or the Bureau) announced it would begin issuing Consumer Financial Protection Circulars (Circulars) to a “broad set of government agencies responsible for enforcing federal…
Continue Reading CFPB to Issue Consumer Financial Protection Circulars to Increase Transparency and Align Enforcement

As nonbanks comprise an ever-greater share of the consumer-finance market, on April 25, 2022, the Consumer Financial Protection Bureau (CFPB, or the Bureau) announced it would invoke its “unused” legal…
Continue Reading CFPB to Examine Nonbank Financial Companies – Including Fintechs – that Pose Risk to Consumers

The Consumer Financial Protection Bureau has expanded its anti-discrimination oversight and enforcement of covered persons to all consumer finance products and services, regardless of whether they involve an extension of…
Continue Reading CFPB Expands Anti-Discrimination by Applying UDAAP to Credit and Non-credit Products

On Jan. 20, 2022, the Board of Governors of the Federal Reserve System (Fed) issued the Money and Payments: The U.S. Dollar in the Age of Digital Transformation paper (Paper)…
Continue Reading Federal Reserve System Takes First Step Toward Creating Its Own Digital Currency

On May 20, 2020, the Office of the Comptroller of the Currency (OCC), which regulates national banks, released a Final Rule intended to strengthen and modernize the implementation of the

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Continue Reading OCC Final Rule Modernizing the Community Reinvestment Act Includes New Incentives for Investing in Indian Country