In his Banking column, Sullivan & Cromwell partner Michael T. Escue discusses the terms and penalties and the key takeaways from the Consumer Financial Protection Bureau's consent order requiring Capital One Bank to refund an estimated $140 million to two million consumers and pay a $25 million civil money penalty over the sale of credit card add-on products.
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First CFPB Public Enforcement Action Offers Insight Into Agency Expectations
New York Law Journal
August 29, 2012
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