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The CFPB announced that it has entered into a consent order with First National Bank of Omaha to settle charges that the bank engaged in unfair or deceptive acts or practices in connection with the marketing and sale of credit card add-on products and the billing of consumers for such products. … 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

Overshadowed by the publicity surrounding the announcement of the CFPB’s settlement of its first enforcement action was the CFPB’s concurrent release of a bulletin providing general guidance on marketing credit card add-on products. While focused on credit card add-on products, the bulletin is also intended to serve as guidance for the marketing of similar products offered in connection with other forms of credit or deposit services. … Continue Reading