In an effort to prevent deceptive conduct, the Consumer Financial Protection Bureau (CFPB) released Policy Statement on April 3rd, which, among other things, expands their definition of “abusive acts and practices.” As debates about how to comply with the CFPB’s new policy statement circulate, Keith Bradley and David Coats take to Law360 to
As 2020 drew to a close, the Ninth Circuit gave the CFPB a victory in Consumer Fin. Prot. Bureau v. Seila Law LLC, 2020 U.S. App. LEXIS 40572 (9th Cir. Dec. 29, 2020), upholding the CFPB’s civil investigative demand (CID) to Seila Law. The case was on remand from the United States Supreme Court, which
The long-running battle over the constitutionality of the CFPB is finally over, and it ended with a whimper. The resolution from the Supreme Court is, practically speaking, about where a panel of the D.C. Circuit left things years ago in PHH.
Companies defending against CFPB enforcement have repeatedly argued that the Bureau is unconstitutional because