A little over 10 years ago, the US Consumer Financial Protection Bureau (“CFPB”) gained authority to enforce a prohibition against abusive acts and practices in connection with the provision of consumer financial products or services. This new authority raised a host of questions about what conduct was abusive and how the CFPB would use this new tool. Five years ago, we reviewed the CFPB’s use of abusiveness in its first four-plus years of existence. This Legal Update summarizes our prior findings and examines the CFPB’s use of abusiveness in the exercise of its enforcement, supervisory and rulemaking authorities over the subsequent five-plus years.
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