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The CFPB Issued a Policy Statement on How It Will Interpret and Apply the Dodd-frank Act’s Abusiveness Standard, Providing Minimal Current Insight, but the Promise and Framework for Future Guidance

As of January 24, 2020, the CFPB issued a Policy Statement setting forth its intent regarding future supervisory and enforcement actions applying the Dodd-Frank Act’s prohibition on “abusive” conduct. This Policy Statement lays out a framework for the CFPB to provide clarity in the future as to what conduct is and is not “abusive”, and indicates that the CFPB wishes to ensure businesses, including banks, are not refraining from offering beneficial and innovative new products and services that would benefit consumers for fear of having the CFPB declare the product or service abusive.

Should I Bank Hemp and CBD Customers?

The most frequently asked question of Wisconsin bankers in 2019 thus far: should I bank customers engaged in hemp or CBD-related activities? Here’s the bottom line: whether or not you choose to bank these customers, and the extent to which you bank such customers, is a business decision.

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