Why Banks Should Be Wary of the CFPB’s Actions Against ACE
Yes, ACE Cash Express is a payday lender, not a bank. But the $10 million settlement the CFPB came to with ACE portends some troubling trends that banks should keep an eye on, such as how the CFPB is using its UDAAP authority to apply the Fair Debt Collection Practices Act to all first-party debt collectors and how the CFPB continues to use enforcement actions to impose requirements rather than the "notice and comment" rulemaking process. [7/24/14]