Consumer Financial Protection Circular 2024-03: Unlawful and Unenforceable Contract Terms and Conditions

The Consumer Financial Protection Bureau (CFPB) has issued Consumer Financial Protection Circular 2024-03, titled, "Unlawful and Unenforceable Contract Terms and Conditions." In this circular, the CFPB responds to the question, "Can persons that include unlawful or unenforceable terms and conditions in contracts for consumer financial products and services violate the prohibition on deceptive acts or practices in the Consumer Financial Protection Act (CFPA)?"