![]() ![]() The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 declares that an act or practice is abusive if it “materially interferes with the consumer’s ability to understand a term or condition of a consumer financial product or service, or takes unreasonable advantage of a consumer.” This would mark an expansion of the scope of the “abusive” prong of the CFPA.ĬFPB Issues Report on Payday Borrower Rollover Fees. In his remarks however, Director Chopra indicated that the CFPB is rejecting this view, and that TRAs and other “debt-like” products are extensions of credit subject to federal consumer financial laws.ĬFPB Director Chopra also stated that the purported abuse of a dominant market position by a company can constitute an abusive CFPA act or practice. Proponents of TRAs have argued that they are not subject to federal consumer financial laws as loans or extensions of credit because employees are not required to repay the cost of training during the course of their employment. If the employee leaves the employer before the period established under the TRA, however, the training cost becomes a debt obligation for the employee. Typically, employees that remain with the sponsoring employer for a set period of time are under no obligation to repay the employer under a TRA. TRAs are generally agreements between an employer and an employee where the employer will incur the cost of certain training programs on the employee’s behalf. ![]() Director Chopra covered a number of regulatory priorities during his remarks, including the applicability of the CFPA to training repayment agreements (TRAs), and whether an alleged abuse of a dominant market position by a company could constitute an abusive act or practice under the CFPA. At the FTC’s Enforcers Summit on April 4, CFPB Director Rohit Chopra issued remarks indicating that the CFPB intends to fully enforce its authority under the Consumer Financial Protection Act (CFPA), including in two new areas. ![]() Regulatory AnnouncementsĬFPB Director Chopra Signals Agency’s Intent to Exercise CFPA Authority in New Areas at Enforcers Summit. ![]() Please reach out if there are other topics you’d like to see us cover or for any additional information. We understand that keeping on top of the rapidly evolving regulatory landscape is more important than ever for businesses seeking to offer new and ground-breaking technologies. We also include links to our articles, blogs, and webinars with more analysis in these areas. In this newsletter, we analyze recent regulatory announcements, recap key enforcement actions, and preview upcoming deadlines and events. Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). ![]()
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