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On August 11, the CFPB published a circular confirming that covered persons and service providers under the Consumer Financial Protection Act (CFPA) may violate the CFPA’s prohibition against unfair acts or practices when they fail to adequately safeguard consumer information. However, the lack of clear substantive standards creates uncertainty as to what the CFPB would deem to be adequate data security practices.… Continue Reading

On February 26, 2020, the CFPB held a symposium on Consumer Access to Financial Records and Section 1033 of the Dodd-Frank Act. Section 1033 addresses consumers’ rights to access information about their own financial accounts, and permits the CFPB to prescribe rules concerning how a provider of consumer financial products or services must make a consumer’s account information available to him or her, “including information related to any transaction, or series of transactions, to the account including costs, charges, and usage data.”… Continue Reading

The CFPB recently released a “Special Edition” of its Supervisory Highlights that focuses exclusively on data accuracy issues in consumer credit reporting and the handling and resolution of consumer disputes. The report describes the observations of CFPB examiners during examinations of both consumer reporting agencies and the creditors and other companies that furnish information to consumer reporting agencies.… Continue Reading

The CFPB recently released a “Special Edition” of its Supervisory Highlights that focuses exclusively on data accuracy issues in consumer credit reporting and the handling and resolution of consumer disputes. The report describes the observations of CFPB examiners during examinations of both consumer reporting agencies and the creditors and other companies that furnish information to consumer reporting agencies.… Continue Reading

The CFPB is extending the comment period on its proposed policy statement that would expand the complaint data that it publicly discloses in its Consumer Complaint Database to include “unstructured” complaint narratives.  In a statement released on July 29, 2014, the CFPB states that it is extending the deadline for comments to be filed from August 22, 2014 to September 22, 2014, 60 days from the date the proposed policy was published in the Federal Register.… Continue Reading

On January 30, 2012, the American Bankers Association delivered a comment letter  to the CFPB in which it expressed strong disagreement with the CFPB’s proposed policy statement on “Disclosure of Certain Credit Card Complaint Data“. The ABA expressed concern that the complaint data will not help and may actually mislead consumers because it is “incomplete, unrepresentative, and unverified.”… Continue Reading