Alert March 05, 2013

CFPB to Focus on “Four Classes of Problems”

At the first bi-annual meeting with the Consumer Advisory Board to discuss consumer-facing financial issues (see February 19, 2013 Alert), Director Richard Cordray discussed “four classes of problems” that the CFPB intends to focus on, which include: (1) deceptive and misleading marketing of consumer financial services and products; (2) products that trigger a cycle of debt for consumers; (3) lack of consumers’ ability to choose their financial service providers (e.g., debt collection, loan servicing, and credit reporting); and (4) the “evil of discrimination.” The CFPB has already voiced its intention to pursue lending discrimination based on both intentional discrimination and the disparate impact theory in a guidance bulletin on compliance with fair lending requirements issued in May 2012 (see May 1, 2012 Alert).