The Consumer Financial Protection Bureau (“CFPB”) announced last week the publication of an Advisory Opinion regarding “Consumer Information Requests to Large Banks and Credit Unions.” The Advisory Opinion applies to “large banks and credit unions”, which means those with $10 Billion or more in assets, and will begin to be enforced against these institutions starting February 1, 2024.
The Advisory Opinion interprets a provision of the Consumer Financial Protection Act (CFPA), 12 U.S.C. 5534(c) (also known as Section 1034(c) of the CFPA), that has not previously been addressed or enforced by the CFPB.