CFPB - Round 2

The Consumer Financial Protection Bureau, the same group that brought you the BOI reporting non-event, has come out with a detailed report that outlines “detailed recommendations to strengthen state-level consumer protection laws and address modern risks in consumer financial markets” plus accompanying documentation saying why. This is all designed to “serve as a resource for state lawmakers and regulators.” It contains 4 primary recommendations (listed without legalistic explanations): 

  • Adoption of regulations banning ‘abusive acts or practices in state legislation; 

  • Removing barriers to effective enforcement by enabling state attorneys general to conduct investigations, issue pre-lawsuit subpoenas, and “pursue equitable relief, punitive damages, and revocation of corporate charters for egregious violators.” Also recommended is the establishment of state funds to reimburse victims when violators cannot. 

  • Cracking down on junk fees via open communication and bans on specific types of fees (hidden or not) that put consumers at a disadvantage. Display of total prices up front is encouraged. 

  • Enhancing consumer data privacy, with a particular focus on prohibiting sale of private/sensitive data to data brokers and further limiting the use of such data. 

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