Keesha N. Warmsby

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Revisiting the Enforceability of Class Action Waivers in Consumer Financial Contracts

On July 19, 2017, the Consumer Financial Protection Bureau (CFPB) published the final Arbitration Agreements Rule (the rule) that would impact the way claims involving consumer financial products and services are handled in the future. The rule prohibits providers of consumer financial products and services from relying on a predispute arbitration agreement that includes an … Continue Reading

CFPB Identifies Hidden Costs and Fees Associated With Online Payday Loans

On April 20, 2016, the Consumer Financial Protection Bureau (CFPB) issued a report regarding online payday lenders’ efforts to debit payments from a borrower’s checking account. Based on an 18-month observation period, the report focused on the hidden costs of online payday and installment loans provided by over 330 lenders. The report is the latest … Continue Reading

CFPB Issues TRID Revision

On February 10, 2016, the Consumer Financial Protection Bureau (CFPB) issued a correction in the Federal Register to the Integrated Mortgage Disclosures Under the Real Estate Settlement Procedures Act (Regulation X) and the Truth in Lending Act (Regulation Z) final rule (TRID Rule). The final TRID Rule, which went into effect on October 3, 2015, … Continue Reading

CFPB Enforces RESPA in its First Appellate Decision of the Director

In the first appeal of an administrative enforcement proceeding before the Consumer Financial Protection Bureau (“Bureau”), the administrative law judge (ALJ) concluded that PHH Corporation, a mortgage lender, referred consumers to mortgage insurance companies in exchange for mortgage reinsurance premiums. The ALJ held that these mortgage reinsurance premiums were considered kickbacks—which are a violation of … Continue Reading

Six Federal Agencies Issue Final Section 342 Standards for Assessing Diversity Policies and Practices of Regulated Entities

On June 9, 2015, six federal agencies (Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve, Federal Deposit Insurance Corporation, National Credit Union Administration, Consumer Financial Protection Bureau, and Securities and Exchange Commission) (collectively, “Agencies”) issued a final interagency policy statement (“Final Policy”) that established joint standards for assessing the … Continue Reading
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