Consumer Credit and Privacy Compliance
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Hudson Cook Insights
Today's Trends in Credit Regulation
Attention Digital Marketers of Financial Products and Services: The CFPB Wants to Be Friends
By Andrea S. Cottrell
Look out, digital marketers! The Consumer Financial Protection Bureau just sent you a friend request. Last month, the CFPB published a press release and an interpretive rule—"Limited Applicability of Consumer Financial Protection Act's 'Time or Space' Exception with Respect to Digital Marketing Providers." article continued
CFPB Charges Payment Processor with Using 'Dark Patterns' to Enroll Consumers into Auto-Renewal Plans
By Michael A. Goodman and Francis Conlon
On October 18, 2022, the CFPB filed suit in Texas federal court against a company that provides online registration and payment processing services to event organizers. The CFPB alleges that the defendant-company deployed "digital duplicity" or "dark patterns" to deceive consumers into signing up for costly membership subscriptions and generating hundreds of millions of dollars in fees in the process. article continued
CFPB Sues Online Lender for Alleged Military Lending Act and UDAAP Violations
By Lucy E. Morris and Michael C. Essiaw
The complaint, filed in the U.S. District Court for the Southern District of New York, alleges that the fintech company violated the MLA when it imposed membership fees on borrowers which, when combined with loan-interest-rate charges, exceeded the MLA's annual percentage rate cap. Further, the Bureau alleges that the company violated the MLA by inserting an illegal arbitration provision in the contracts and by failing to make the requisite disclosures to borrowers. article continued
CFPB Bites of the Month - October Top 10: Ghosts, Goblins & the Spooky CFPB
By Eric L. Johnson, Justin B. Hosie, and Byron J. Carter
In this month's Top 10 article, we share some of our top "bites" for the prior month covered during the October 19, 2022, webinar.
So, what happened last month?
Extra Bite: CFPB Releases Special Edition of Supervisory Highlights on Student Loan Servicers and University-Owned Lenders article continued