Consumer Financial Protection Bureau Law Blog

Big Brother is Watching. . .Your Bank Account: Cordray to Testify About CFPB’s Data Collection Efforts

Orwellian telescreens have not achieved ubiquity, but the CFPB’s massive data collection efforts in recent months feel little less intrusive to industry participants.  Thanks to an ongoing fishing expedition, CFPB will soon have amassed one of the largest databases of consumer financial information in the country.  CFPB will soon know in great detail how millions of Americans spend their cash, use their credit cards, manage their debt, and use other financial services (and how industry participants manage those services on a minute level). Read More ›

CFPB Amends International Remittance Transfer Rules, But Still Falls Short

The Consumer Financial Protection Bureau celebrated the holidays by proposing revisions to its pending international remittance transfer regulations.  The new revisions, circulated by the Bureau on December 21 and published in the Federal Register on December 31 of last year, propose to change some of the reporting and dispute resolution requirements and procedures for international remittance transfers under Regulation E. Some the proposed changes track proposals made to the Bureau by industry participants last year, but the Bureau also failed to clarify certain key terms and refused to adopt other important industry proposals. Read More ›

CFPB and Chicago Enter Into Historic (And Troubling) Agreement

Last week (12/5/12), the CFPB announced an extraordinary partnership with the City of Chicago to share information regarding fraudulent and predatory practices by financial institutions. 

This arrangement is troubling on a number of levels, but hardly surprising.  The action is certain to broaden the scope of the CFPB’s gaze, as the agreement includes a commitment by the City to directly report alleged violations of consumer financial protection laws and regulations to the CFPB, thereby granting extraordinary leverage to the City.  In fact, the agreement effectively turns the City’s enforcement infrastructure into an investigative arm of the CFPB, and vice versa. Read More ›

CFPB Announces New Appeals Process For Adverse Findings: CFPB Still Judge, Jury and Final Word

Last week’s announcement of the CFPB’s new “appeal process” for supervised entities offers little solace to those organizations subject to an adverse finding or compliance rating by the Bureau. Pursuant to Bulletin 2012-07 (Bulletin) released by the CFPB, “Financial service providers, including depository institutions, under CFPB’s jurisdiction may request a review of a less than satisfactory compliance rating (a 3, 4, or 5) or any underlying adverse finding set forth in the relevant examination report, or adverse findings conveyed in a supervisory letter.” If this sounds too good to be true, that’s because it is. Read More ›