The CFPBs Inquiry Into Junk Fees: What It Means For Consumer Financial Services Providers
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The CFPB\\u2019s recently-issued request for information takes aim at what the CFPB labels \\u201cjunk fees\\u201d charged by consumer financial services providers. We discuss the types of fees targeted in the RFI, particularly fees related to deposit accounts and mortgages, and the impact of existing regulatory requirements on the CFPB\\u2019s initiative. We also examine the CFPB\\u2019s authority to address so-called \\u201cjunk fees,\\u201d consider possible short- and long-term actions the CFPB could take in response to the RFI, offer steps providers can take to prepare for greater scrutiny of ancillary fees and possible legal challenges, and describe the CFPB readiness reviews that Ballard Spahr attorneys are conducting to assist providers in assessing the permissibility and disclosure of fees charged in connection with their consumer products and services.
Alan Kaplinsky, Ballard Spahr Senior Counsel, hosts the conversation, joined by John Culhane, Richard Andreano, and Ron Vaske, partners in the firm\\u2019s Consumer Financial Services Group.
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