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...
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...
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...
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...
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...