Consumer Financial Services

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On Oct. 3, 2023, the U.S. Supreme Court heard oral arguments in Consumer Financial Protection Bureau (CFPB) v. Community Financial Services Association of America (CFSA) (Docket No. 22-448), a case that raises the question of whether the CFPB’s funding structure, by which it receives funding directly from the Federal Reserve rather than via a congressional appropriation, violates the U.S. Constitution’s Appropriations Clause and, if so, what the appropriate remedy should be.
Continue Reading Supreme Court Hears Oral Argument on Constitutionality of CFPB’s Funding

On March 30, after years of rulemaking efforts, the Consumer Financial Protection Bureau (CFPB) issued a final rule implementing Section 1071 of the Dodd-Frank Act. Small business lenders, if they haven’t already, must put in place rigorous data collection techniques, implement security firewalls, and update employee training by their listed compliance date.

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  • CFPB proposes rule requiring nonbanks to “register” with the CFPB if they include certain terms and conditions in their form contracts, including in their website terms of use
  • The registry would serve as a public database tracking firms that use form contracts to waive or limit certain consumer rights
  • The CFPB intends to
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On Nov. 9, 2022, the New York Department of Financial Services (NYDFS) issued a proposed second amendment to its 2017 cybersecurity regulation for financial service companies.[1] In July 2022, NYDFS issued a draft version of the changes, but the current amendment has significant changes. Most of the proposed changes will take effect 180 days…