Remove compliance circulars
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CFPB Issues Guidance on Two Bank “Junk Fee” Categories

Troutman Sanders

Specifically, the CFPB published a compliance bulletin , cautioning against charging across-the-board depositor fees to consumers who deposit a check that bounces, as well as a circular on what the CFPB refers to as “surprise” overdraft fees —the CFPB’s way of referring to authorize positive, settle negative practices (APSN).

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Troutman Pepper Weekly Consumer Financial Services Newsletter

Troutman Sanders

On February 12, FFIEC issued a statement of principles related to valuation discrimination and for member entities to consider in their consumer compliance and safety and soundness examinations. For more information, click here.

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The CFPB’s 2022 Fair Lending Annual Report to Congress

Collection Industry News

Through our enforcement and examination activity, interpretive rules and advisory opinions, circulars, and other tools, we continue to make clear that fair lending must be a top priority for all financial institutions.

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Q3 Industry Insights: Economic Challenges, Compliance Considerations and a Silver Lining

True Accord

The next day, the CFPB published a circular about requirements to safeguard consumer data, specifically citing practices that “are likely to cause” substantial injury like inadequate data security measures. For a good snapshot of what compliance looks like today, check out our Collections & Compliance page.

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Troutman Pepper Weekly Consumer Financial Services COVID-19 Newsletter

Troutman Sanders

The CFPB published a Consumer Financial Protection Circular to remind the public, including those responsible for enforcing federal consumer financial protection law, of creditors’ adverse action notice requirements under the Equal Credit Opportunity Act. For more information, click here.

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Troutman Pepper Weekly Consumer Financial Services Newsletter

Troutman Sanders

On August 18, the FDIC issued guidance to FDIC-supervised institutions to address certain consumer compliance risks associated with assessing multiple non-sufficient funds fees, arising from the re-presentment of the same unpaid transaction. For more information, click here. For more information, click here.

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Troutman Pepper Weekly Consumer Financial Services Newsletter

Troutman Sanders

On November 10, the CFPB issued a circular on its recent revelation that consumer reporting agencies and furnishers may be evading their obligation under the Fair Credit Reporting Act to conduct reasonable investigation of consumer disputes. For more information, click here. For more information, click here.