The CFPB has issued a bulletin warning credit card issuers that offer certain promotional APRs of the risk that they may be engaging in deceptive and/or abusive acts or practices when making solicitations for such offers even if such solicitations are in compliance with Regulation Z.  

The bulletin focuses on promotional offers that allow consumers to transfer a credit card balance or make a purchase that will be subject to a zero or low APR for a stated time period. … Continue Reading

Lisa Madigan, Illinois Attorney General, recently filed a motion in a state court lawsuit against a for-profit college and its owners and operators seeking leave to further amend her complaint to add new counts alleging that the defendants’ practices were unfair and abusive under the federal Consumer Financial Protection Act (CFPA) (Title 10 of Dodd-Frank). … Continue Reading

The U.S. Chamber of Commerce’s Center for Capital Markets Competitiveness has sent a detailed letter to Director Cordray in which it criticizes the CFPB’s approach of “regulation by enforcement settlement combined with issuance of brief guidance statements” in lieu of engaging in rulemaking or otherwise soliciting public input. 

In the letter, the Chamber expresses its strong belief that “if the Bureau identifies areas in which it wants to fundamentally alter the rules, it should take the time to write new standards rather than rely on one-off enforcement and press release “warnings” to other regulated companies.” … Continue Reading

It has been reported that Director Cordray, in a briefing on March 22, stated that CFPB enforcement actions are “in process” but was unwilling to specify when the first cases might be filed. This is consistent with the CFPB’s statement in its first annual report  to Congress on federal enforcement of the Fair Debt Collection Practices Act filed on March 20 that the CFPB “currently is conducting non-public investigations of debt collection practices to determine whether they violate the FDCPA or the Dodd-Frank Act.”Continue Reading