CFS+ partner Tyler Engar was recently quoted in a Law360 article on the CFPB's lawsuit against TransUnion. The CFPB's lawsuit accuses TransUnion of violating commitments it made in a 2017 consent order to stop using deceptive offers to bait consumers into signing up for credit monitoring subscriptions. TransUnion fully denies the accusations. Consumer regulatory attorneys agree the CFPB's suit exemplifies the aggressive enforcement style the consumer financial industry can expect from the regulator going forward.

"If you're a company that operates on this negative option model or has business practices that could be implicated in this TransUnion case, I would be pretty aware of what the consent order commitments were and what the CFPB's allegations are because you never know if you're next," said Engar.