This week’s podcast episode: A close look at the FDIC’s supervisory guidance and class action litigation regarding multiple non-sufficient funds fees arising from re-presentment of the same unpaid transaction
CFPB Monitor
SEPTEMBER 22, 2022
We discuss each of the three categories of risk identified in the guidance (consumer compliance, third-party, and litigation), plaintiffs’ legal theories in class actions challenging NSF fees, the role of arbitration clauses and contract language in defending class actions, the FDIC’s suggested risk mitigation practices, issues to consider in navigating (..)
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