On October 4, 2022, the Consumer Financial Protection Bureau (CFPB) entered into a consent order with Choice Money, a New York nonbank remittance transfer provider involving violations of the Remittance Transfer Rule (“Remittance Rule”), Subpart B of Regulation E, 12 C.F.R. §§ 1005.30 to 1005.36, and the Consumer Financial Protection Act.… Continue Reading

In a decision issued earlier this summer, the U.S. Court of Appeals for the Seventh Circuit vacated the district court’s order awarding restitution, mandating civil penalties, and issuing an injunction in an action brought by the CFPB against two mortgage-assistance relief companies and four lawyers associated with the companies.  The decision imposes significant limitations on the Bureau’s ability to recover both monetary and injunctive relief in enforcement actions.… Continue Reading

The Office of the Comptroller of the Currency recently issued a revised Policies and Procedures Manual (PPM) for assessing civil money penalties (CMP).  The PPM applies to CMPs assessed against all national banks, federal savings associations, federal branches and agencies licensed by the OCC, and institution-affiliated parties.  It also applies to bank service companies and service providers.… Continue Reading