On June 4, 2024, the CFPB issued a circular warning against the use of unlawful or unenforceable terms and conditions in contracts for consumer financial products or services. The CFPB warns they will take action against companies and individuals that deceptively slip coercive contract clauses that censor and restrict individual freedoms and rights into their fine print.

The circular explains how and when fine print tricks and intimidation in contracts for consumer financial products and services may violate the Consumer Financial Protection Act’s prohibition on deceptive acts and practices. The CFPB clarified that companies may still be liable even if the unenforceable terms are borrowed from form templates or widely available contracts.

Read the CFPB’s press release here.

The full circular can be found here.

Adam Witmer

Adam Witmer is a speaker, author, and founder of the Compliance Cohort. Adam has taught hundreds of seminars and training sessions to thousands of bankers throughout the United States and teaches on all areas of regulatory compliance. Adam has written five e-books that he never published, hit a grizzly bear while driving in a National Park, and is an award winning photographer and musician (though he no longer takes photos nor plays any instruments). In his spare time, Adam can be found kayaking on the lake, doing taekwondo with his kids, working on his (project) house, or spending time with his family.

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