Chris Capruso

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Investigation Tag Team: The FTC and the State of Arizona

Sep 17, 2024 | lexology.com | Chris Capruso |Brooke Conkle |Christopher Carlson

Click here to listen to the audio. In this episode, Chris Carlson, an associate in the Regulatory, Investigations, Strategy and Enforcement (RISE) practice, joins Brooke and Chris to discuss how federal and state regulators are collaborating on consumer protection investigations. The team discusses a recent order and action against an Arizona-based auto dealer for multiple Unfair or Deceptive Acts or Practices (UDAP) violations.
OCC Issues “Buy Now, Pay Later” Guidance to Banks

Dec 7, 2023 | lexology.com | Chris Capruso |Jason Cover |Mark J. Furletti |Taylor Gess |James Kim |Ethan G. Ostroff | +4 more

Yesterday, the Office of the Comptroller of the Currency (OCC) issued guidance to banks on managing the risks associated with “buy now, pay later” (BNPL) lending. Specifically, the bulletin addresses BNPL loans that are payable in four or fewer installments and carry no finance charges. The stated aim of the OCC’s guidance is to ensure that these loans are offered in a manner that is safe, sound, and compliant with applicable laws and regulations.
Federal Agencies Announce Increased Regulations Z and M Dollar Thresholds for Exempt Consumer Credit and Lease Transactions, and Higher Threshold for Exemption from Mortgage Loan Appraisal Requirements

Nov 14, 2023 | lexology.com | Chris Capruso |Caleb Rosenberg |Alan D. Wingfield

On November 13, the Consumer Financial Protection Bureau (CFPB) and the Federal Reserve Board (Fed) announced increased dollar thresholds used to determine whether certain consumer credit and lease transactions in 2024 are exempt from Regulation Z (Truth in Lending) and Regulation M (Consumer Leasing).
CFPB Calls for Increased Specificity and Accuracy on Reasons for Credit Denials When Lenders Employ Artificial Intelligence

Sep 19, 2023 | lexology.com | Chris Capruso |Taylor Gess |Ethan G. Ostroff |Alan D. Wingfield |Joshua McBeain |Chris Willis | +3 more

When using artificial intelligence (AI) or complex credit models, can lenders rely on the checklist of reasons provided in Regulation B sample forms for adverse action notices? According to today’s guidance issued by the Consumer Financial Protection Bureau (CFPB or Bureau), the answer to that question is, in many circumstances, no.
CFPB Announces Annual Threshold Adjustments for Credit Cards and Mortgages

Sep 19, 2023 | lexology.com | Chris Capruso |Ethan G. Ostroff |Alan D. Wingfield

The Consumer Financial Protection Bureau (CFPB) has issued a final rule adjusting the Truth in Lending Act (TILA) dollar amounts for certain provisions, including under the Home Ownership and Equity Protection Act of 1994 (HOEPA), and the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), where appropriate, based on the annual percentage change reflected in the consumer price index (CPI). The rule takes effect on January 1, 2024.
CFPB’s Policy Statement on Abusiveness (Part 2)

May 24, 2023 | lexology.com | Chris Capruso |Stefanie Jackman |Caleb Rosenberg |Chris Willis

Click here to listen to the audioPlease join Troutman Pepper Partner Chris Willis and his colleagues Stefanie Jackman, Caleb Rosenberg, and Chris Capurso for the second installment of our special two-part series about the Consumer Financial Protection Bureau’s (CFPB) recent policy statement on abusiveness. In Part 2, the panel discusses specific examples cited in the policy statement, as well as lessons learned about what constitutes abusiveness and what doesn’t from the CFPB’s perspective.