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Credit Slips Blog
What’s the Democrats’ Legislative Agenda in Financial Regulation and Consumer Protection?
The extent of the Blue wave last night caught a lot of the Democratic policy establishment unprepared. Democrats are suddenly going to be able to move legislation, but not override…
Consumer Financial Services Law Monitor
The OCC’s Final Debanking Report and the CFPB’s Response: Key Takeaways
By Lori Sommerfield, Chris Willis, Lane Page
On October 14, the Office of the Comptroller of the Currency (OCC) released its final report on the results of its review of debanking at the nine then-largest national banks…
Consumer Financial Services Law Monitor
CFPB’s 2025 Fair Lending Report Chronicles Major Shift in Fair Lending Examination, Supervision, and Enforcement
By Lori Sommerfield, Chris Willis, Lane Page
On October 1, the Consumer Financial Protection Bureau (CFPB or Bureau) released its Fair Lending Report for 2025, documenting a significant overhaul of the Bureau's fair lending program under current…
Consumer Financial Services Review
California Enacts its Fair Lending Examination Act
California Governor Newsom signed a slate of legislation on September 30, 2026, including Assembly Bill 801, the California Fair Lending Examination Act. The Act (or AB 801) establishes a new…
Consumer Financial Services Law Monitor
FTC Hits the Brakes on Disparate Impact
By Brooke Conkle, Chris Capurso
In this episode of Moving the Metal, hosts Brooke Conkle and Chris Capurso break down the FTC's landmark policy statement officially abandoning disparate impact enforcement and what it means for…
Consumer Financial Services Law Monitor
Point-of-Sale Finance Series: Auto Finance — Dealer Risk, Lien Perfection, and Compliance Essentials for Market Entrants
By Jason Cover, Brooke Conkle, Chris Capurso
In this crossover episode of The Consumer Finance Podcast and Moving the Metal, Jason Cover is joined by colleagues Brooke Conkle and Chris Capurso from Troutman Pepper Locke's Consumer Financial…
Consumer Finance Monitor
FTC Abandons Disparate Impact and “Unfair Discrimination” Theories: A Major Shift in Federal Consumer-Protection Law
By Richard J. Andreano, Jr., John L. Culhane, Jr., Alan S. Kaplinsky, Ronald K. Vaske
The Federal Trade Commission (FTC) has taken a major step toward dismantling two theories of discrimination. In a new Policy Statement Regarding Disparate-Impact Claims and “Unfair Discrimination” Claims, the FTC…
Consumer Financial Services Law Monitor
FTC Abandons Disparate Impact Theory
By Chris Capurso, Brooke Conkle, Lori Sommerfield, Chris Willis
On August 7, the Federal Trade Commission (FTC) issued a policy statement announcing that it will no longer pursue claims based on disparate impact or “unfair discrimination” theories under any…
Consumer Financial Services Law Monitor
Regulators Signal Heightened Scrutiny of Lending to Non-Work Authorized Borrowers
By Lori Sommerfield, Chris Willis, Taylor Gess, Lane Page
Yesterday, the federal banking regulators issued new interagency guidance directing supervised financial institutions to take a closer look at credit risk when lending to individuals who are not legally authorized…
Consumer Financial Services Law Monitor
CFPB and FinCEN Sharpen Focus on Non‑Work Authorized Populations, Ability to Repay, and BSA/AML Risk
By Keith J. Barnett, Chris Willis, Lori Sommerfield, Carlin McCrory, Lane Page
Federal regulators recently took two coordinated steps that significantly shift expectations for how lenders and banks treat non‑work authorized individuals and their employers. On June 5, the Consumer Financial Protection…