As expected, the CFPB today released final results of its consumer arbitration study as mandated by Section 1028 of the Dodd-Frank Act. Section 1028 provides that the CFPB, “by regulation, may prohibit or impose conditions or limitations on the use of” pre-dispute arbitration agreements concerning consumer financial products or services if it finds doing so “is in the public interest and for the protection of consumers.”
We will be reviewing the study carefully and will provide our reactions once we complete our review. While the CFPB did not reveal what its next steps will be, its findings as described in its press release about the study seem to set the stage for a rulemaking that will not be favorable to the industry. In our legal alert issued today, we have listed the study’s key findings as described by the CFPB in its press release and provide our initial observations.
On March 18, 2015, Ballard Spahr attorneys will hold a webinar “The CFPB’s Arbitration Study: Where Do Things Go From Here?” from 12 p.m. to 1 p.m. ET. More information and the registration form are available here.