Author: J.H. Jennifer Lee

J.H. Jennifer Lee

Jenny represents large and regional banks, card issuers, mortgage bankers or mortgage insurance companies, online lenders, Fin Tech firms, private equity firms with consumer-facing specialty finance strategies, or any “covered person” delineated in the Bureau’s statute, title X of the Dodd-Frank Act. As a lawyer who worked inside the Consumer Financial Protection Bureau (Bureau) Office of Enforcement for several years beginning with the Bureau’s founding, Jenny possesses unique experience that she draws upon to provide clients with defense strategies for enforcement by or litigation with the Bureau....

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The Long Arm of the CFPB

On the fifth birthday of the Consumer Financial Protection Bureau (“CFPB”), Dorsey attorneys discuss the CFPB’s investigatory powers and explain – through an analysis of three important cases – how the events of early 2016 reveal a changing tide. Click here to read the article published in Corporate Counsel.

“Nonbank” Lender Seeks Injunction Restraining CFPB Administrative Action

On May 9, 2016, Integrity Advance, LLC and its CEO James Carnes filed suit against the Consumer Financial Protection Bureau (“CFPB”) in United States District Court for the District of Columbia seeking to enjoin the CFPB from continuing to prosecute an administrative enforcement action under the Consumer Financial Protection Act (“CFPA”) in which the CFPB alleged unfair, deceptive or abusive lending practices.

Problems With the CFPB’s Argument: An Analysis of the D.C. Circuit Oral Arguments on Statute of Limitations

What began as a challenge to the Consumer Financial Protection Bureau’s (“CFPB”) $109 million enforcement ruling against the mortgage company PHH Corp. (“PHH”) for alleged violations of the Real Estate Settlement Procedures Act (“RESPA”), has evolved into a broader discussion about the constitutionality of the agency itself. As demonstrated in the closely watched federal appeal brought by PHH, critical developments occurred earlier this month that have implications for the agency’s future enforcement approach.

When is an Administrative Action Barred by the Dodd-Frank Act’s Three-Year Statute of Limitations? Never, According to the CFPB

Corporate defendants are entitled to the protections afforded by statutes of limitations, which bar claims for conduct long-past and are “vital to the welfare of society.” Recently, however, the Consumer Financial Protection Bureau (“CFPB”) has doubled down on its position that the statute of limitations is inapplicable to enforcement actions brought in a certain category of proceedings.