Here, authored by Seth Frotman and Lorelei Salas. Here is a particularly intriguing excerpt:
Now that companies are being held accountable for charging [certain] unlawful fees, they have switched to new, underhanded tactics to try to continue to extract junk fee revenue from people. For example, we have seen some debt collectors unlawfully amend consumers’ existing contracts to try to bless the very fees that they are otherwise prohibited from charging. These companies don’t give the person any real choice in the matter: they are simply told that they are required to sign paperwork changing the terms of their original agreement if, for example, they want to continue using certain payment methods. In fact, the CFPB has cited one or more companies for these practices in our supervisory examinations. * * *
I wonder what will happen to efforts to block junk fees under the next CFPB director. On the one hand, someone committed to using the market to police misconduct should oppose junk fees because such fees undermine the functioning of the market. On the other hand, sometimes claimed justifications are not the true justifications.