Skip navigation

Articles

Analysis

Corner Post: The Statute of Limitations for APA Challenges

July 22, 2024

In Corner Post v. Board of Governors, FRS, the U.S. Supreme Court determined that a claim under the Administrative Procedure Act (“APA”) does not accrue for purposes of the applicable statute of...

Administrative Procedure Act Judicial Review of Agency Actions Litigation Rulemaking & Administrative Procedure

Analysis

The Loper Bright Decision and the Chevron Doctrine

June 29, 2024

On June 28, 2024, the Supreme Court issued its opinion in Loper Bright Enterprises v. Raimondo, holding that the Chevron Doctrine was inconsistent with the Administrative Procedure Act. For financial...

Administrative Procedure Act Agency Interpretations & Guidance Judicial Review of Agency Actions

Analysis

CFPB's Final Rule Creating a Registry of Nonbank Public Orders

June 10, 2024

On June 3, 2024, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) published its final rule creating a registry (“Registry”) of nonbank covered persons subject to certain agency and court...

Consumer Financial Protection Act Consumer Financial Protection Bureau Enforcement Actions Nonbank Financial Companies

Analysis

Supreme Court Upholds the CFPB's Funding Mechanism (CFPB v. CFSA)

May 16, 2024

On May 16, 2024, the U.S. Supreme Court affirmed the mechanism established by Congress to fund the Consumer Financial Protection Bureau (CFPB). The case was brought by trade associations whose...

Appropriations Consumer Financial Protection Act Consumer Financial Protection Bureau Litigation

Analysis

CFPB Credit Card Late Fee Final Rule

March 5, 2024

Today, the CFPB issued its final rule on credit card late fees under TILA. This memorandum provides a brief overview of the final rule. New Safe Harbor for Credit Card Late Fees: The new safe harbor...

Consumer Fees & Pricing Consumer Financial Protection Bureau Credit Cards TILA