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While most attention is focused on the CFPB, state attorneys general are very active in investigating and enforcing state laws relating to consumer financial services (and often federal laws when incorporated into state law or when using their Dodd-Frank authority). We first discuss the CPD’s priorities and how they are determined; use of its state law UDAP authority and available remedies; enforcement of federal law; and collaboration with the CFPB and other state AGs. We also discuss how a company’s self-identification/self-remediation of violations factors into the CPD’s enforcement approach. We then discuss key issues of CPD concern and enforcement activity in specific areas, including mortgage servicing, auto sales and financing, debt collection, fintech/new technologies, and buy-now-pay-later.
Alan Kaplinsky, Senior Counsel in Ballard Spahr’s Consumer Financial Services Group, hosts the conversation joined by John Grugan and Adrian King, partners in the firm’s Litigation Group, who defend companies facing state Attorneys General enforcement initiatives.
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