Following its usual practice of setting standards by edict, the Bureau of Consumer Financial Protection has laid out an extensive framework that brings a wide range of consumer-finance actions and inactions within the scope of enforcement sanctions governing acts or practices that are not only unfair or deceptive, but also abusive. As a result, consumer-finance providers and the third parties on which they often rely have considerably more legal and reputational risk even as consumers may be better insulated from actions that disadvantage or even harm their financial prospects. Much of the new policy requires providers to protect the most vulnerable of any possible consumer for all aspects of a product or service, structuring all aspects of product offerings, pricing, marketing, infrastructure, and …
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