Glen Trudel

Glen Trudel

Ballard Spahr LLP

Contact  |  View Bio  |  RSS

Latest Publications

Share:

OCC consumer protection standards in new Bulletin may influence CFPB Debt Sales Examinations of Banks

As noted in our recent Alert, the Office of the Comptroller of the Currency (OCC) has issued Bulletin 2014-37 on Consumer Debt Sales (the “Bulletin”). The Bulletin addresses the application of consumer protection requirements...more

8/7/2014 - Banks CFPB Debt OCC

Comptroller of the Currency Publishes Guidance on Debt Sales Arrangements and Agreements

The Office of the Comptroller of the Currency’s (OCC’s) new Bulletin 2014-37 on Consumer Debt Sales represents the agency’s latest guidance on this topic since providing a written statement a year ago to the Senate...more

8/7/2014

CFPB Issues Report on the Use of Remittance Histories in Credit Scoring

On July 3rd, the CFPB released a Report on the Use of Remittance Histories in Credit Scoring (the “Report”). Section 1073(e) of the Dodd-Frank Wall Street Reform and Consumer Protection Act required the CFPB Director to study...more

7/7/2014 - CFPB Credit Reports

FTC Announces Settlement with Debt Collector over Alleged FDCPA Violations

The Federal Trade Commission (FTC) recently announced a settlement with a Houston debt collection company and its individual owner related to alleged violations of the Fair Debt Collection Practices Act (FDCPA). This action...more

7/2/2014

Department of Education proposal on campus financial products expected in July

We recently commented that financial institutions offering financial products to college students, including debit or prepaid cards, under agreements with colleges should be planning now for the possible advent of new...more

6/24/2014 - Colleges Debit Cards Disclosure Requirements DOE Financial Products Prepaid Payment Products Students Title IV Universities

Elizabeth Warren and other congressional members urge rulemaking by the Department of Education re: regulating college/bank...

On April 22nd, Senator Warren, nine other Senators, and 14 members of Congress sent a letter (the “Letter”) to Secretary of Education Duncan urging that the Department of Education (DOE) exercise its rulemaking authority to...more

4/29/2014 - Banks Colleges Debit Cards Department of Education Elizabeth Warren Prepaid Payment Products Students

CFPB payday loan proposal for rulemaking is coming, but timing of its publication remains unclear

At the Practicing Law Institute’s 19th Annual Consumer Financial Services Institute held on Monday in New York City, Meredith Fuchs, Associate Director & General Counsel for the CFPB delivered the opening keynote address,...more

4/10/2014 - CFPB HMDA Payday Loans

Collection Letter Requiring Written Dispute Violated FDCPA, Fourth Circuit Holds

A collection letter violated the Fair Debt Collection Practices Act (FDCPA) because it stated that the debtor could only dispute the debt in writing, the U.S. Court of Appeals for the Fourth Circuit has ruled. The Fourth...more

2/7/2014 - Debt Collection FDCPA

Federal Reserve Publishes Guidance on Managing Outsourcing Risk of Service Provider Relationships

The Federal Reserve recently added to the growing body of regulatory guidance on the topic of financial institution management of service provider outsourcing relationships by issuing its Guidance on Managing Outsourcing Risk...more

12/12/2013 - Bank Service Providers Banks Board of Directors Corporate Officers Federal Reserve OCC Outsourcing Risk Management

FTC Settles First Case Challenging Debt Collector’s Use of Text Messages

The Federal Trade Commission recently announced that it had settled a case representing its first action challenging a debt collector’s use of text messages. In its complaint, the FTC alleged that the defendant debt...more

10/4/2013 - Debt Collection FDCPA FTC TCPA Texting

CFPB Plans Continued Scrutiny of Credit Card Practices

The Consumer Financial Protection Bureau has issued a report on how the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act) has affected the consumer credit card market. The report describes the...more

10/3/2013 - CARD Act CFPB Credit Cards

OCC Signals Increased Agency Attention to Debt Sales

The Office of the Comptroller of the Currency (OCC) has made clear that all national banks and federal savings associations can expect increased scrutiny of their debt sales practices, as well as supervisory guidance...more

7/19/2013 - Banks Debt Debt Collection OCC Sales

Collection Letter Requiring Written Dispute Violated FDCPA, Second Circuit Holds

A collection letter violated the Fair Debt Collection Practices Act (FDCPA) because it stated that the debtor could only dispute the debt in writing, the U.S. Court of Appeals for the Second Circuit has ruled....more

6/7/2013 - Debt Collection Debtors FDCPA Writing Requirement

Merchants Challenge Constitutionality of New York’s ‘No Credit Card Surcharge’ Law

Five merchants and their principals have filed a lawsuit in federal district court in New York challenging the constitutionality of a state law that prohibits merchants from imposing a surcharge on credit card purchases. New...more

6/6/2013 - Credit Cards Debit and Credit Card Transactions Due Process Excise Surcharges First Amendment Fourteenth Amendment Merchant Fees Sherman Act

CFPB Issues Second Annual Report on FDCPA Activities

The Consumer Financial Protection Bureau’s second annual report to Congress on enforcement of the Fair Debt Collection Practices Act (FDCPA) confirms that debt collection will continue to be a major CFPB focus in 2013....more

3/27/2013 - CFPB Debt Collection Dodd-Frank FDCPA FTC

Collection Letter Inviting Debtor To Call Toll-Free Number Violated FDCPA, Third Circuit Holds

A collection letter violated the Fair Debt Collection Practices Act (FDCPA) because its invitation to call a toll-free number could be read by the “least sophisticated debtor” to permit the debt to be effectively disputed by...more

3/14/2013 - Debt Collection Debtors FDCPA Notice Requirements

Prevailing Defendant Can Recover Costs in FDCPA Suit Not Filed in Bad Faith, Supreme Court Rules

A prevailing defendant in a Fair Debt Collection Practices Act (FDCPA) case can recover costs even without a court finding that the plaintiff filed suit in bad faith and for the purpose of harassment, the U.S. Supreme Court...more

3/1/2013 - Attorney's Fees CFPB Debt Collectors FDCPA General Revenue Corp. Legal Costs Prevailing Party SCOTUS

FTC Continues To Target Debt Collectors and Debt Relief Companies

The Federal Trade Commission’s continuing focus on the debt collection and debt relief industries was clearly demonstrated by several recently announced lawsuits and settlements....more

2/11/2013 - CFPB Debt Collection Debt Collectors Debt Settlement Services Debt-Relief Industry FDCPA FTC Section 5 Telemarketing Sales Rule

FTC Issues Debt Buying Industry Study

The Federal Trade Commission has issued a report, The Structure and Practices of the Debt Buying Industry, which the FTC has described as “the first of its kind” empirical study of debt buyers. ...more

2/1/2013 - CFPB Debt Debt Buyers Debt Collection FTC

19 Results
|
View per page
Page: of 1