The CFPB’s Increased Focus on Medical Financing Products

Editor's Note: This article, authored by Jason Cover, Mark Furletti, Stefanie Jackman & Chris Willis previously appeared in Troutman Pepper’s Consumer Financial Services Law Monitor and is re-published here with permission. 

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Over the course of the last year, the Consumer Financial Protection Bureau (CFPB or Bureau) has increased its scrutiny of medical financing products, such as medical credit cards and installment loans. In July 2023, the CFPB and other federal agencies launched an inquiry into medical payment products, discussed here. Last week, when the CFPB announced its proposed rule to ban the reporting of medical debt on consumer reports, discussed here, it stated it was considering action related to medical financing products. Then this week, the CFPB published a blog examining how financial institutions market their products to healthcare providers in an effort to ensure “consumers aren’t pushed into medical payment products.” The CFPB’s ongoing discourse on this topic signals a potential regulatory crackdown may be coming.

Highlights from the CFPB’s blog include:

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