The Consumer Financial Protection Bureau (CFPB) released its final Advisory Opinions Policy (AOP) on Monday, November 30, setting forth procedures to facilitate the submission of requests for advisory opinions from it by interested parties. Simultaneously, the CFPB issued two advisory…
Continue Reading <a href="/blogs/70561"><h3>The Consumer Financial Protection Bureau to Issue Advisory Opinions to Answer Interpretive Questions</h3></a>

On September 11, 2018, an interagency statement was issued by the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corp., the National Credit Union Administration and the Consumer…
Continue Reading <a href="/blogs/69746"><h3>When Is Supervisory Guidance By Banking Regulators Not A Rule To Live By? When There Is A Rule That Says So.</h3></a>

A national lender, USAA Federal Savings Bank, entered into a consent order with the Office of the Controller of the Currency (“OCC”), which included an $85 million civil money penalty for alleged “unsafe or unsound” banking risk management, compliance processes,…
Continue Reading Alleged SCRA and MLA Violations Lead To Lender Being Assessed A $85 Million Penalty Under OCC Consent Order

It has been several months since consumers began filing lawsuits against various companies for failing to issue refunds or changing their refund policies after the COVID-19 pandemic began.
Continue Reading <a href="/blogs/69551"><h3>MLB Ticket Refunds Did Not Moot Claims </h3></a>

The U.S. Supreme Court ruled on June 29 that the Director of the Consumer Financial Protection Bureau (CFPB) cannot constitutionally be subject to removal only for cause, as provided by the Dodd-Frank Wall Street Reform and Consumer Protection Act of…
Continue Reading Supreme Court Rules That the CFPB Director Must Be Removable at Will

Since the outbreak of COVID-19, we have seen numerous class action lawsuits filed against companies for changing their refund policies to ones that have a negative impact on consumers or for not giving full monetary refunds for cancelled events or…
Continue Reading Do Not Make Promises to Consumers that Cannot Be Kept: Look Out For Consumer Litigation For Failing to Honor Refund Policies

On May 29, 2020, the OCC issued a final rule on permissible interest on loans that are sold, assigned, or otherwise transferred.
Continue Reading OCC Issues Final Rule on Interest Rates Being “Valid When Made”