Category Archives: Unfair & Deceptive Acts & Practices (UDAP), including Discrimination

CFPB dismisses enforcement action against Solo Funds

The stipulation of dismissal is here. Here’s some of what the Bureau had said earlier about the case: The Bureau alleges that SoLo’s advertisements and loan disclosures tout no-interest loans when, in fact, virtually all loans on the SoLo Platform include a lender “tip” that goes to the lender, a SoLo “donation” that goes to […]

Eleventh Circuit Finds Convenience Fees Violate FDCPA

As the federal government as we know it is eliminated, it is good to see a positive pro-consumer opinion out of the Eleventh Circuit today. In Booze v. Ocwen Loan Servicing, the Court of Appeals considered a question that had divided district courts–whether the FDCPA prohibits loan servicers from collecting “pay-to-pay” or “convenience” fees for the […]

CFPB Director Chopra ends term with prolific last month

The notice arrived Saturday morning. Rohit Chopra’s tenure as director of the Consumer Financial Protection Bureau had ended — by the new administration — well short of the completion of his five-year term. The past week was filled with grumbling from various industry corners and inquiring journalists wondering why Chopra had not already been forced […]

In mixed decision, 5th Circuit continues stay of pro-consumer airline rules

The US airline industry challenged DOT rules issued by the last administration that required airlines to disclose certain fees upfront when potential customers search for itineraries, The petitions for review included both constitutional and statutory challenges, as well as procedural challenges. A motions panel of the Fifth Circuit had stayed the Rule, and today, the […]

Fifth Circuit Vacates FTC CARS Rule

Yesterday, over a dissent, the Fifth Circuit vacated the FTC’s CARS rule, which protected consumers from unfair and deceptive practices by car dealers. While the challengers lobbed many wide-ranging arguments that called into question the FTC’s authority broadly, the Fifth Circuit based its ruling solely on the agency’s failure to issue an Advanced Notice of […]

Departing DOT takes action against airlines for “chronically delayed flights”

Over the past two weeks, the Department of Transportation has taken actions against several airlines for what the Department refers to as “chronically delayed flights,” suggesting violations of consumer protections.  According to DOT, the airlines are effectively misleading customers as to the actual times of the flights, because these flights so infrequently depart at those […]

Ninth Circuit holds consumer lender waived 7th Amendment argument against CFPB

CashCall is a lender that makes unsecured, high-interest loans to consumers via a related company incorporated under the laws of the Cheyenne River Sioux Tribe. In 2022, the Ninth Circuit decided CFPB v. CashCall, in which it affirmed a district court’s finding, after a bench trial, that CashCall committed an unfair, deceptive, or abusive act […]

Adam Feibelman paper argues that the CFPB should have authority over the Community Reinvestment Act

Adam Feibelman of Tulane University has written Relocating the Community Reinvestment Act. Here’s the abstract: The Community Reinvestment Act was enacted in 1977 to address the failure of financial institutions to provide credit and financial services in low-income communities, especially Black neighborhoods. The Act is part of a family of legal regimes, including the Home […]

“FTC, Illinois Attorney General Take Action Against Grubhub for Harming Diners, Workers, and Small Businesses”

The FTC reports: “Grubhub will pay $25 million to settle charges from the Federal Trade Commission and the Illinois Attorney General that the food delivery firm engaged in an array of unlawful practices including deceiving diners about delivery costs and blocking their access to their accounts and funds, deceiving workers about how much money they […]

Man bites dog as Trump sues under UDAP for polling claims

The complaint is here. and concerns the finding announced shortly before the election that the poll had Harris leading Trump among Iowans. The suit is against the Des Moines Register, the pollster and Gannett; the UDAP statute in question is Iowa Code § 714H.3(1). That statute provides: A person shall not engage in a practice […]