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ARTICLE · 08 MAY 2024

These Are Junk Fees

Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
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Hogan Lovells Cadwalader

Hogan Lovells Cadwalader

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In the Consumer Financial Protection Bureau's ("CFPB's") most recent Supervisory Highlights, published on April 24th, the agency identified a wide variety...

United StatesFinance and Banking

In the Consumer Financial Protection Bureau's ("CFPB's") most recent Supervisory Highlights, published on April 24th, the agency identified a wide variety of fees that were improperly charged to mortgage borrowers. As compared to other "junk fee" efforts by the CFPB, almost all of the fees identified in this report were charged to the borrower either in violation of their agreement or for reasons that had nothing to do with the borrower's actions, but instead could be ascribed to mistakes made by their servicers. Nevertheless, the CFPB used the publication of this document as a means to publish a press release that beats the drum regarding their final rule that severely restricts credit card late fees because they are "junk fees." That rule has been severely challenged by the credit card industry.

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