On May 10, 2023, the Consumer Financial Protection Bureau (“CFPB”) issued Consumer Financial Protection Circular 2023-02 (“CFPC 2023-02” or the “Circular”). In CFPC 2023-02, the CFPB considers the following question: After consumers have closed deposit accounts, if a financial institution unilaterally reopens those accounts to process a debit (i.e., withdrawal, ACH transaction, check) or deposit, […]