CFPB's NSF Fee Proposal Is More Than It Seems

By Alan S. Kaplinsky and Kristen Larson
February 8, 2024

Writing for The Financial Brand, Alan S. Kaplinsky and Kristen Larson explained how the Consumer Financial Protection Bureau's proposed non-sufficient funds fee regulation, which might at first not seem noteworthy, deserves bankers' serious attention.

"Simply stated, the CFPB’s incredibly broad approach to unfair, deceptive or abusive acts or practices (UDAAP) in the proposal could readily be expanded to attack other lawful bank fees," the co-authors wrote.

Mr. Kaplinsky is the former longtime Practice Leader of the firm's Consumer Financial Services Group, of which Ms. Larson is a member. Both are frequent contributors to the Consumer Finance Monitor podcast and Consumer Finance Monitor blog.

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