CFSAA v. CFPB: Unpacking the Fifth Circuit Decision That CFPB's Funding Structure Violates the Constitution 

October, 2022 - Friedman Christopher K

Last Wednesday, the United States Court of Appeals for the Fifth Circuit held that the CFPB's automatic funding structure violates the Constitution. Because the decision calls into question virtually all of the CFPB’s actions since its creation, it has wide-ranging potential implications for all financial services industries. Please join us for a lunch-time webinar as we unpack the Fifth Circuit’s decision and what it means for your business. We plan to address these topics:

  • The history of the CFPB's Payday Lending Rule and litigation filed by CFSAA
  • Expected next steps in the Fifth Circuit and potential Supreme Court petition for certiorari
  • Implications for small-dollar lenders, mortgage companies, banks, and other financial services industries
  • Other pending litigation challenging the CFPB’s funding structure
  • Implications for other independent regulatory agencies with self-funding structures, including the OCC, FDIC, and Federal Reserve
  • Compliance and enforcement challenges for both the CFPB and regulated industries

Webinar Recording

 

 

 

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