Breaden Douthett

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The Consumer Financial Protection Bureau (CFPB) has issued a Consent Order addressing alleged disparate treatment by banks in overseas territories of the United States.  The Consent Order illuminates the CFPB’s approach to disparate treatment claims and provides a caution for financial institutions in their collection practices. On Aug. 23, 2017, the CFPB issued a Consent Order regarding the charge and credit card practices of American Express Centurion Bank and American Express Bank, FSB (together, Amex…