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Consumer Protection

Banking 101: Paying Attention to Ratios and Why It Matters

Ratios. Percentages. Ranges. In banking, metrics matter. Too much liquidity? Too little liquidity? Increasing number of accounts more than 30 days past due? Increasing number of defaults? Too few new deposit accounts? Too small of a gap in interest rates? A small change in any one of the metrics measuring a bank’s performance can be the first indicator of a potential issue that could later turn…

A first step on the road to clarity: CFPB Abusive Acts or Practices Statement of Policy

On January 24, 2020, the Consumer Financial Protection Bureau (CFPB) published “Statement of policy regarding prohibition on abusive acts or practices” (Statement).1  The CFPB’s intention in publishing the Statement was “To convey and foster greater certainty about the meaning of abusiveness”. The Statement provides little to immediately clarify the definition of abusiveness. It does create a…


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