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CFPB Issues Report on Unlawful ‘Junk Fees’ Uncovered in Deposit Accounts, Multiple Loan Servicing Markets

By Benjamin M. Saul, W. H. Langley Perry, Jr. & Janiell "Alexa" Gonzalez on March 16, 2023
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On March 8, 2023, the Consumer Financial Protection Bureau (CFPB) released the Supervisory Highlights Junk Fees Special Edition (Report) detailing unlawful fees the agency found in deposit accounts and in multiple loan servicing markets during CFPB examinations completed between July 1, 2022, and Feb. 1, 2023.

Click here to continue reading the full GT Alert.

Photo of Benjamin M. Saul Benjamin M. Saul

Benjamin Saul is a shareholder in the firm’s Financial Regulatory and Compliance Practice. For two decades, Ben has handled high-stakes regulatory, enforcement, and litigation matters for corporate and individual clients in the consumer finance, specialty finance, fintech, and banking sectors.

Ben has helped

…

Benjamin Saul is a shareholder in the firm’s Financial Regulatory and Compliance Practice. For two decades, Ben has handled high-stakes regulatory, enforcement, and litigation matters for corporate and individual clients in the consumer finance, specialty finance, fintech, and banking sectors.

Ben has helped clients navigate dozens of contentious supervisory, enforcement, and litigation matters involving the Consumer Financial Protection Bureau (CFPB), and has been a leader in the private bar on CFPB matters since the Bureau’s inception in 2011. He also routinely assists clients in matters involving the FTC, DOJ, HUD, OCC, FRB, FDIC, state financial services authorities, state attorneys general, and state civil rights commissions. Ben’s enforcement matters have concerned fair lending and servicing, unfair deceptive and/or abusive trade practices, other federal and state consumer finance laws, AML/BSA, troubled or failed banks, fiduciary duties, financial institution fraud, supervisory ratings, and other safety and soundness issues.  These matters often have involved parallel proceedings by multiple enforcement agencies and/or private parties.

Ben also advises lenders, servicers, alternative financial service providers, and money service businesses on product and service development, licensing, compliance program enhancement, and the applicability of federal and state consumer credit and other financial services laws. He frequently helps clients understand how financial services law maps onto new technologies and innovative products, having worked on matters involving big data, artificial intelligence, marketplace and online lending, blockchain, digital assets and cryptocurrencies, digital banking, and payment systems.  In addition, Ben provides financial services regulatory support for corporate and capital markets transactions.

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Photo of W. H. Langley Perry, Jr. W. H. Langley Perry, Jr.

Langley Perry focuses his practice on federal and state regulatory compliance and state licensing for companies engaged in money transmission, consumer lending and loan servicing, commercial and residential mortgage services, debt collection, and other financial services.

Langley works on nationwide state money transmitter…

Langley Perry focuses his practice on federal and state regulatory compliance and state licensing for companies engaged in money transmission, consumer lending and loan servicing, commercial and residential mortgage services, debt collection, and other financial services.

Langley works on nationwide state money transmitter, lending, servicing, and other license acquisition projects. He provides compliance advice across a broad range of laws applicable to banks, money services businesses and non-bank consumer finance companies. He has experience handling Bank Secrecy Act/Anti-Money Laundering (BSA/AML) and Office of Foreign Assets Control (OFAC) compliance program reviews and development as well as matters involving the Financial Crimes Enforcement Network (FinCEN) and the Foreign Corrupt Practices Act (FCPA). He also advises clients on matters involving the Consumer Financial Protection Bureau (CFPB) and other federal and state regulatory authorities with oversight of consumer financial and payments products and services.

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Photo of Janiell "Alexa" Gonzalez Janiell "Alexa" Gonzalez

Janiell A. Gonzalez focuses her practice on helping bank and non-bank financial institutions navigate the federal and state regulatory environment governing payments, lending, and consumer financial services. She represents and advises industry leaders in the development and implementation of emerging payment products, including…

Janiell A. Gonzalez focuses her practice on helping bank and non-bank financial institutions navigate the federal and state regulatory environment governing payments, lending, and consumer financial services. She represents and advises industry leaders in the development and implementation of emerging payment products, including Internet- and mobile-based payment products and services. Janiell regularly assists clients with federal money services business registrations, nationwide state money transmitter and lending licensing applications, and ongoing licensing compliance issues. Janiell helps clients design Bank Secrecy Act (BSA)/Anti-Money Laundering (AML)/Office of Foreign Asset Control (OFAC) compliance policies and procedures, conducting independent risk assessments, and providing company-wide training on these topics.

Janiell also serves as the Deputy General Counsel for the Hispanic National Bar Association’s charitable arm, HNBA VIA, where she provides advice on a broad range of legal issues affecting the organization.

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  • Posted in:
    Banking, Finance and Securities
  • Blog:
    Financial Services Observer
  • Organization:
    Greenberg Traurig, LLP
  • Article: View Original Source

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