Consumer Financial Protection Circular 2023-02: Reopening Deposit Accounts That Consumers Previously Closed

Samenvatting

The Consumer Financial Protection Bureau (CFPB) has issued Consumer Financial Protection Circular 2023-02, titled, "Reopening Deposit Accounts That Consumers Previously Closed." In this circular, the CFPB responds to the question, "After consumers have closed deposit accounts, if a financial institution unilaterally reopens those accounts to process a debit (i.e., withdrawal, ACH transaction, check) or deposit, can it constitute an unfair act or practice under the Consumer Financial Protection Act (CFPA)?"