On July 24, 2024, the Consumer Financial Protection Bureau (“CFPB”) released a Consumer Financial Protection Circular (Circular 2024-04 click here) informing entities offering consumer financial products or services as described by the Consumer Financial Protection Act (“CFPA”) and their service providers that overbroad confidentiality agreements signed by employees could potentially violate the rights of whistleblowing employees under Section 1057 of the CFPA and thus be a violation of the CFPA.
