Overview
Steptoe partner Benjamin Saul and associates Tarrian Ellis, and Nathaniel Sans authored an article titled "CFPB Proposal Defining Consumer Risk May Add Uncertainty," which appeared in Law360.
The article explores how the CFPB’s proposed rule issued on August 26 would define “risks to consumers” under the Consumer Financial Protection Act as conduct likely to cause significant harm directly tied to consumer financial products or services, aiming to create a more consistent and limited framework for supervising nonbank entities.