CFPB, Federal Agencies, State Agencies, and Attorneys General
The CFPB has issued a new compliance bulletin (2016-03) on incentive programs. The issuance of the bulletin reflects the CFPB’s increased focus on such programs.
To assist clients in preparing for greater regulatory scrutiny, Ballard Spahr attorneys will conduct a webinar on December 14, 2016, from 12 p.m. to 1 p.m.… Continue Reading
The CFPB has reissued its guidance on service providers which was formerly titled CFPB Bulletin 2012-03, and as published in the Federal Register on October 26, 2016, is now titled “Compliance Bulletin and Policy Guidance 2016-02.”
The reissued guidance includes an amendment that the CFPB described as “needed to clarify that supervised entities have flexibility [in their risk management program for service providers] and to allow appropriate risk management.” … Continue Reading
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
