On its third anniversary, we can look back on the Consumer Financial Protection Bureau and make certain observations as follows: 1. The CFPB looks to the end substance of transactions. Unlike other regulatory agencies that in many cases looked at form over substance, the CFPB will ignore structures, agreements, and programs altogether when it perceives them to be a “sham” transaction. More than ever lenders need to look to the substance of what they are doing because the CFPB has the power and willingness to declare almost anything a “sham” and regulate or enforce accordingly.
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Ari Karen is an experienced litigator and speaker who has focused his practice in representing financial institutions in both government investigations and litigation before state and federal trial and appellate courts nationwide.
Mr. Karen’s practice is diverse, representing clients on matters concerning banking regulations, Dodd Frank financial reform laws, contractual disputes, employment and labor statutes, wage-hour class actions, employment discrimination and fair lending matters, whistleblower complaints and non-competition claims, among others.