Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 14 SEPTEMBER 2012

CFPB Exam Procedures For Consumer Reporting Companies

Venable LLP
Explore more from Venable LLP

The Consumer Financial Protection Bureau ("CFPB") continues to move forward with implementation of its nonbank supervision program by releasing the procedures it will use in examining credit bureaus and other consumer reporting companies.

United StatesConsumer Protection
Jonathan Pompan
Jonathan Pompan

The Consumer Financial Protection Bureau ("CFPB") continues to move forward with implementation of its nonbank supervision program by releasing the procedures it will use in examining credit bureaus and other consumer reporting companies.  According to the Bureau, "these procedures are a field guide for CFPB examiners looking to check that these companies are following the law."  The CFPB's authority to supervise consumer reporting companies takes effect September 30, 2012.

The Dodd-Frank Act gave the CFPB authority to supervise "larger participants" in the consumer financial markets as defined by rule.  In July 2012, the CFPB identified a market for consumer reporting and defined larger participants to include companies in that market that have more than $7 million in annual receipts.  According to the CFPB, its supervisory authority will cover an estimated 30 companies that account for about 94 percent of the market's annual receipts. 

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

New York City’s Click-to-Cancel Rule: What Businesses Need To Know

New York City has enacted the nation's first municipal click-to-cancel rule, requiring businesses to provide clear disclosures, simple cancellation processes, and advance renewal notices for subscription services. With approximately 30 states already implementing similar regulations and the federal landscape in flux following the FTC's vacated rule, companies now face an increasingly complex patchwork of compliance obligations. The rule takes effect October 1, 2026, and imposes penalties ranging from $525 t
United StatesConsumer Protection
Skadden, Arps, Slate, Meagher & Flom LLP
Skadden, Arps, Slate, Meagher & Flom LLP
Article

FCC Replaces TCPA “Revoke All” Rule: New Category-Specific Opt-Out Rules For Robocalls And Robotexts

The Federal Communications Commission has fundamentally altered how businesses must handle consumer opt-out requests under the Telephone Consumer Protection Act, replacing the broad "revoke all" mandate with a more nuanced, category-specific approach for informational messages. This regulatory shift allows companies to maintain separate consent tracks for different types of non-marketing communications while preserving stricter opt-out requirements for telemarketing messages. The Updated Order introduces ne
United StatesConsumer Protection
Bass, Berry & Sims PLC
Bass, Berry & Sims PLC
Article

Amway To Pay $225 Million Over Alleged False Earnings Claims And Fabricated Sales

The FTC and Washington state secured a record $225 million settlement from Amway and affiliated groups over allegations they misled recruits about earnings potential while pressuring them to buy products with little retail opportunity. The complaint reveals that over three-quarters of U.S. product volume was sold to IBOs themselves rather than retail customers, with fabricated sales reporting masking the recruitment-driven model. The settlement's injunctive provisions establish new standards for earnings cl
United StatesConsumer Protection
Frankfurt Kurnit Klein & Selz PC
Frankfurt Kurnit Klein & Selz PC
Article

FTC Asks Whether Platform Ad Tools Fuel Impersonation Scams

The Federal Trade Commission is exploring whether digital platforms should bear greater responsibility for preventing impersonation ads that falsely pose as legitimate businesses or government agencies. Through an Advance Notice of Proposed Rulemaking, the agency seeks public input on potential amendments to its existing Impersonation Rule, examining how ad-optimization tools and platform practices...
United StatesConsumer Protection
Greenberg Traurig
Greenberg Traurig
Article

The Coming State-Law Litigation Wave Of 2026-27: “Subscription Trap” Class Actions

State-law class actions targeting automatic renewal and subscription practices are accelerating, creating significant litigation risk for companies that rely on recurring revenue models. Recent settlements demonstrate that even technical compliance failures can lead to seven-figure exposure, with California, Illinois, and Virginia statutes driving the most aggressive litigation.
United StatesConsumer Protection
Benesch, Friedlander, Coplan & Aronoff LLP
Benesch, Friedlander, Coplan & Aronoff LLP
Article

NCAA Enjoined From Enforcing New Fifth-Year Eligibility Rule

A federal court has issued a nationwide injunction blocking the NCAA from enforcing its new five-year eligibility rule against Division I athletes who graduated high school in 2022. The ruling creates immediate compliance challenges for athletic departments as they navigate roster management, revenue-sharing caps, and potential penalties while the NCAA appeals the decision.
United StatesConsumer Protection
Buchanan Ingersoll & Rooney
Buchanan Ingersoll & Rooney
Article

CONGRESS FIRES BACK?: New Bill Seeks To Revive Written Consent Rule Under TCPA

Congress has introduced the Stop Spam Calls Act, directing the FCC to revise the definition of prior express written consent under the TCPA to require one-to-one seller consent and logical relevance between sellers and website content. This legislative move comes as the Fifth Circuit questions whether written consent is even required under the TCPA, creating a fascinating tension between congressional intent and judicial interpretation that could reshape telemarketing compliance.
United StatesConsumer Protection
Troutman Amin LLP
Troutman Amin LLP
Article

Virginia’s Initial Draft Of Adult-use Marijuana Regulations – What You Should Know And What Questions Remain

Virginia's Cannabis Control Authority has released its initial draft of adult-use marijuana regulations, outlining application fees, license caps, and the approval process for the state's anticipated July 2027 launch of recreational cannabis sales. While the draft provides crucial details on licensing requirements and ownership restrictions, significant questions remain about the application timeline and evaluation criteria that will determine which entities receive coveted permits.
United StatesConsumer Protection
Foley Hoag LLP
Foley Hoag LLP
Video

NOT MARKETING: Court Reminds TCPAWorld That Debt Collection Just Doesn’t Trigger The DNC Rules (Video)

A federal court in Maryland dismissed both TCPA claims against debt collector TrueAccord, ruling that debt collection calls don't qualify as marketing solicitations under DNC rules and that the company's dialing system doesn't meet the definition of an automatic telephone dialing system. The decision reinforces the distinction between debt collection communications and marketing calls under federal telecommunications law.
United StatesConsumer Protection
Troutman Amin LLP
Troutman Amin LLP