Author: Laura Pfenning

HIGHLIGHTS: CASE SUMMARY: On January 30, 2025, the CFPB entered into a consent order with the Company, alleging violations of the Consumer Financial Protection Act (“CFPA”) and Electronic Fund Transfer Act (“EFTA”). The Bureau found that the Company allegedly engaged in deceptive acts and practices by misrepresenting ATM withdrawal fees and failing to provide accurate… Continue reading CFPB Takes Action Against Fintech for Alleged Deceptive ATM Fee Disclosures and Violations of the Electronic Fund Transfer Act

In this article, we share a timeline of our monthly “bites” for 2024 applicable to the credit card industry. The year saw the CFPB give a fair amount of attention to credit card products, with a focus on pricing. The proposed rule to limit late fees on credit cards became final (Bite 5), though is… Continue reading CFPB Bites of the Month – 2024 Annual Review – Credit Cards

The Federal Trade Commission (FTC) and the Colorado Attorney General filed suit January 16 against a major property management company, alleging deceptive practices under Section 5 of the FTC Act, the Gramm-Leach-Bliley Act (GLBA), and the Colorado Consumer Protection Act (CCPA). The lawsuit centers on the scope of disclosure of rents and fees in rental housing advertising and leasing.… Continue reading Outside the Rule, Inside the Court: FTC Throws a Curve for Rental Housing Rent and Fee Disclosures in Ads and Leasing

In this article, we share a timeline of our monthly “bites” for 2024 applicable to consumers protected by nondiscrimination and military protection laws. 2025 will likely bring more of the same, particularly in the area of enforcement of military protection laws, as protection of servicemembers is generally a matter of bipartisan concern. Bite 15: The… Continue reading CFPB Bites of the Month – 2024 Annual Review – Nondiscrimination and Military Protection Law

HIGHLIGHTS: CASE SUMMARY: On January 14, 2025, the CFPB filed a lawsuit against the Bank, alleging violations of the CFPA, TISA, and its implementing Regulation DD. The lawsuit alleges that the Bank deceived customers who were enrolled in the Bank’s high interest savings deposit product. According to the allegations in the complaint, the Bank created… Continue reading Hudson Cook Enforcement Alert: CFPB Fines National Bank and Bank Holding Company for Alleged Violations of the CFPA, TISA, and Regulation DD in Connection with High Interest Deposit Products

HIGHLIGHTS: CASE SUMMARY: On January 16, 2025, the CFPB announced that it issued a stipulation and consent order against the Company, to resolve allegations that the Company violated the CFPA, the EFTA, and Regulation E. The consent order alleges that the Company committed unfair acts or practices in violation of the CFPA by failing to… Continue reading Hudson Cook Enforcement Alert: CFPB Settles with Peer-to-Peer Payment App Company for Allegedly Failing to Prevent Fraud and Investigate Disputes

In this article, we share a timeline of our monthly “bites” for 2024 applicable to the auto finance industry. Bite 9: CFPB Issues Report on Price Complexity On April 30, 2024, the CFPB released a report on price complexity.The report addressed the CFPB’s research into how complex pricing options can impact consumer decision making.Participants in the experiments… Continue reading CFPB Bites of the Month – 2024 Annual Review – Auto

In this month’s article, we share some of our top “bites” for the prior and current month covered during the November 2024 webinar. Bite 12: CFPB Issues Statement about Medicare Beneficiaries Billing On October 31, 2024, the CFPB issued a statement about Medicare beneficiaries billing, warning about improper billing and collection practices. Specifically, the CFPB and the… Continue reading CFPB Bites of the Month – November 20, 2024 – CFPB Take Me Home, Country Roads

On December 17, 2024, the Federal Trade Commission (FTC) finalized its Trade Regulation Rule on Unfair or Deceptive Fees (16 CFR § 464), otherwise known as the “Junk Fees” Rule, targeting specific industries with a narrowed “activities-based” scope. This significant shift moves away from the proposed rule’s broad coverage of industries to instead cover live-event ticketing and… Continue reading RPM Alert: FTC’s Final Rule on Unfair and Deceptive Fees in Ads and Leasing: Key Takeaways for Apartment and Short-Term Rental Housing Providers

HIGHLIGHTS: CASE SUMMARY: On December 9, 2024, the CFPB entered into a consent order with the Company, alleging violations of the Consumer Financial Protection Act (“CFPA”) and Fair Debt Collection Practices Act (“FDCPA”) with respect to its collection practices involving student-loan borrowers who defaulted on Federal Family Education Loan Program (“FFELP”) loans. FFELP borrowers have… Continue reading Hudson Cook Enforcement Alert: CFPB takes action against Student Loan Servicer for Allegedly Delaying Default Rehabilitation Process to Acquire Collection Fees