On May 26, the Consumer Financial Protection Bureau (the Bureau or CFPB) issued its third Circular, emphasizing that creditors must adhere to the Equal Credit Opportunity Act (ECOA) and
Continue Reading CFPB Circular 2022-03: Complex Lending Algorithms Cannot Excuse Failure to Provide Specific, Principal Reasons for an Adverse Credit Determination
On May 19, 2022, the Consumer Financial Protection Bureau (CFPB or Bureau) issued an interpretive rule (Section 1042 Interpretive Rule 5 19 2022) confirming that the Consumer Financial
Continue Reading Deputizing State AGs: CFPB Issues Broad New Interpretive Rule on States’ Ability to Enforce Federal Consumer Protection Laws
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
On May 16, 2022, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a report regarding COVID-19 response metrics based upon its “observations from data obtained by 16 large mortgage
Continue Reading CFPB Metrics Report Shows Increased Scrutiny of Borrower Access to Servicers, Information, and Loss Mitigation Opportunities
On May 9, 2022, the Consumer Finance Protection Bureau (CFPB or the Bureau) issued an advisory opinion to clarify that the Equal Credit Opportunity Act (ECOA) and Regulation B (Reg
Continue Reading CFPB Advisory Opinion Clarifies that ECOA Applies Throughout Credit Lifecycle
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
The Consumer Financial Protection Bureau (CFPB) has begun information-gathering inquiries into multiple companies that offer “buy now, pay later” (BNPL) credit to merchants and consumers, citing concerns about “accumulating debt,
Continue Reading CFPB Begins Scrutinizing Companies Using ‘Buy Now, Pay Later’ Credit
On June 28, 2021, the Consumer Financial Protection Bureau (CFPB, or the Bureau) issued its Final Rule amending RESPA Regulation X to provide significant foreclosure protections to borrowers.
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Continue Reading Update: CFPB Finalizes Pandemic Mortgage Servicing Rules
Welcome to the Spring 2021 issue of Greenberg Traurig’s Financial Services Insights Newsletter. This newsletter reviews certain significant cases and legal developments affecting the financial services industry.