Enforcement Trends

New York Attorney General Announces Results of Investigation into National Bank's Subsidiary over Improper Fees

On August 19, 2015, the New York Attorney General’s Office announced an interim agreement with a subsidiary of a national banking organization over allegations that the bank charged improper fees on customer’s inactive accounts. The bank managed consumer investment accounts and charged a variety of fees for account management services….

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FTC Releases 2014 Annual Financial Acts Enforcement Report


On June 9, 2015, the Federal Trade Commission (“FTC”) announced that it provided its 2014 Annual Financial Acts Enforcement Report (the “Report”) to the Consumer Financial Protection Bureau (“CFPB”) and the Federal Reserve Board.  The 23-page Report, dated May 29, 2015, provided information about enforcement and related activities involving Regulation Z (Truth in…

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1Q 2015 Enforcement Trends

For the first quarter of 2015, Consumer Finance Enforcement Watch tracked 46 instances of enforcement activity taken against a consumer finance service provider.  Not surprisingly, the year started off slow with only 9 enforcement actions taken in January, likely due to agencies wrapping-up actions before year-end 2014. The 46 actions ranged…

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