An Analysis Of The CFPB’s Abusiveness Claims: Part 2

Law360, New York (March 21, 2016, 11:45 AM EDT) -- Ori Lev

Chris Shelton In the first part of this two-part series, we discussed the nuts and bolts of how the Consumer Financial Protection Bureau has interpreted the four prongs of the Dodd-Frank Act’s prohibition on “abusive” acts or practices through CFPB enforcement cases. In this final part, we will explore the broader patterns that have emerged through those cases and what they mean for the financial services industry going forward.


As we discussed in the first part, the Dodd-Frank Act added a new definition...
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