On June 4, the CFPB issued Circular 2024-03 (“Circular”) warning that the use of unlawful or unenforceable terms and conditions in contracts for consumer financial products or services may violate the prohibition on deceptive acts or practices in the Consumer Financial Protection Act. We previously drafted a blog post and Law360 article about this circular. Since the publication of the Circular, our Consumer Financial Services Group has been engaging with many clients to evaluate their consumer contracts and processes to determine ways to comply with the Circular.

If you will be attending the meeting in San Diego later this week of the American Bar Association Committee on Consumer Financial Services and you would like to accompany us on a one hour deep dive in which we explain the methods we are using to conduct reviews of consumer contracts to make them compliant with the Circular, we will be leading a roundtable discussion on Friday, August 13 at 9 a.m. PT at the Marriott Marquis Marina District in Marine Ballroom D, South Tower.