Month: March 2024

The Chamber of Commerce’s case against the Consumer Financial Protection Bureau challenging the CFPB’s late fee rule is moving to DC. See our ALERTS of Mar. 6 and Mar. 8, 2023. On March 28, after considering briefs by both the Chamber of Commerce and the CFPB Read More

The Court of Appeals for the Third Circuit held that trusts areb“covered persons” subject to the enforcement authority in the Consumer Financial Protection Act (CFPA). CFPB v. National
Collegiate Master Student Loan Trust, No. 22-1864 (3rd Cir. March19, 2024).
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As expected, the U.S. Chamber of Commerce, the American Bankers Association, the Consumer Bankers Association and three Texas trade groups filed suit against the Consumer Financial Protection Bureau (“CFPB”) on March 7 to halt implementation of the CFPB’s newly finalized rule on credit card late fees.
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Over a year after the issuance of a notice of proposed rulemaking to amend the Regulation Z safe harbor for credit card late fees, the Consumer Financial Protection Bureau (“CFPB”) announced the final rule to slash the credit card late fee safe harbor from its current rate of $30 for the first violation and $41 thereafter to a flat $8 late fee for card issuers with more than 1 million open accounts.
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The Consumer Financial Protection Bureau (“CFPB”) has issued guidance on kickbacks and steering in the context of (i) digital comparison-shopping tools, whether on websites, in applications or through chatbots, and (ii) lead generation.
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State and federal regulators continue to press on compliance and oversight issues affecting both fintechs and their bank partners. See, e.g., our ALERTS of Sept. 22, Nov. 10 and Dec. 27, 2022, and Apr. 28, June 12 and Aug. 8, 2023.
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