Credit Cards

CFPB's Monthly Complaint Report Spotlights Debt Collection Issues, Trends in Credit Card Complaints

On March 28, 2017, the Consumer Financial Protection Bureau (CFPB) released Volume 21 of its Monthly Complaint Report (the “Report”).  The purpose of the Report is, in part, to educate consumers and financial institutions on major consumer issues—which it does by providing a high-level analysis of trends in consumer complaints, focusing on one or two…

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FTC Issues Order Against Debt Relief Company for Alleged Misrepresentations

On February 27, 2017, the Federal Trade Commission (FTC) entered into a stipulated order for permanent injunction and monetary judgment with defendants United Debt Counselors, LLC, a debt relief company, and its principals, banning the defendants from making misrepresentations about financial products and services and requiring the defendants to pay a $9…

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CFPB Releases 2016 Rulemaking Agenda

On May 18, 2016, the Consumer Financial Protection Bureau (CFPB) announced its Spring 2016 Rulemaking Agenda, setting forth its current initiatives. In its latest installment of the semi-annual update, the Bureau highlighted its recent (or imminent) activity in several high-profile areas, including arbitration and payday lending.  Below are highlights of…

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The CFPB Targets Lender's Credit Card Division With More Than $200MM In Penalties

The Consumer Financial Protection Bureau (CFPB) has set its sights on debt collection practices again.  In April, we wrote about the CFPB’s $63 million settlement with a mortgage servicer, Green Tree Mortgage, in part for Green Tree’s alleged treatment of mortgage debt.  On July 8, 2015, the CFPB once again demonstrated it was…

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Add-On Products Continue To Present Litigation Risks For Lenders

The Consumer Financial Protection Bureau’s recent action against two credit card vendors regarding credit monitoring and identity theft protection services is a reminder of the legal risks associated with certain add-on products. The July 1 settlement, in which the CFPB found that the vendors misled customers about the benefits of…

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CFPB Director Faces Tough Questions Before House Committee on Financial Services

On March 3, 2015 CFPB Director Richard Cordray appeared before the House Committee on Financial Services to deliver testimony regarding the Bureau’s work.  Director Cordray spent much of his semiannual address touting the Bureau’s efforts in the mortgage space.  In his written statement, Director Cordray commented on the Bureau’s Qualified…

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CFPB Warns Credit Card Issuers Against Deceptive Marketing of Promotional APR Offers

On September 3, 2014, the CFPB issued a Bulletin warning credit card issuers about deceptive marketing of promotional annual percentage rate (APR) offers.  According to the CFPB, it has observed solicitations that offer an initial low APR for certain kinds of transactions (such as convenience checks, deferred interest rate purchases, or…

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Recent DOJ & CFPB Consent Orders Highlight ECOA Risks For Servicers

Synchrony Bank (formerly known as GE Capital Retail Bank) made two direct mail offers to its credit card holders, but it did not send the offers to Spanish-speaking customers.  The Bank self-reported its actions, resulting in consent orders with the Consumer Financial Protection Bureau and the Department of Justice, which…

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