Jeremy T. Rosenblum

Jeremy T. Rosenblum

Ballard Spahr LLP

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Tribally-affiliated lenders file opposition to CFPB’s petition to enforce CIDs

We recently reported that the CFPB has filed a petition in U.S. District Court for the Central District of California seeking to enforce the civil investigative demands (CIDs) it issued in June 2012 to three...more

4/22/2014 - CFPB Internet Lenders Payday Loans Tribal Loans

Hints of future payday rule-making

Laura Udis, the CFPB’s program manager for the payday lending industry, spoke on April 10 in Los Angeles on a panel sponsored by the American Bar Association Consumer Financial Services Committee. CFPB staff members are...more

4/17/2014 - CFPB Internet Lenders Payday Loans

CFPB amends CashCall complaint

The CFPB has filed an amended complaint in its lawsuit against CashCall and several related companies that funded, purchased, serviced and collected online payday loans to identify additional states in which the loans...more

4/17/2014 - CashCall CFPB Internet Lenders Payday Loans

CFPB files petition in CA federal court to enforce CIDs issued to tribal payday lenders

The CFPB recently filed a petition in U.S. District Court for the Central District of California seeking to enforce the civil investigative demands (CIDs) it issued in June 2012 to three tribally-affiliated payday lenders. A...more

4/14/2014 - CFP CID Payday Loans Tribal Loans

Bankers Win Latest Interchange Battle

The U.S. Court of Appeals for the District of Columbia Circuit recently reversed a lower court decision and upheld the interchange rules adopted by the Federal Reserve Board (FRB) under the so-called Durbin Amendment to the...more

3/27/2014 - Banks Dodd-Frank Durbin Amendment Rules Federal Reserve Interchange Fees

Tribal Affiliation Not a Bar to FTC Authority

In an enforcement action alleging violations of the Federal Trade Commission Act (FTC Act) and other federal laws by tribally affiliated entities that operated an Internet payday lending operation, a Nevada federal court...more

3/25/2014 - FTC Jurisdiction Payday Loans Tribal Loans

CFPB to hold March 25 payday loan field hearing

The CFPB has announced that it will be holding a field hearing on payday loans on March 25, 2014 in Nashville, Tennessee. The event will feature remarks by Director Cordray and testimony from consumer groups, industry...more

3/14/2014 - CFPB Deposit Advances Payday Loans

Director Cordray confirms 2014 focus on payday and other small-dollar loans

According to a report by Kim Chipman and Carter Dougherty of Bloomberg, in a Q&A with state attorneys general that followed a speech today in Washington, D.C. to the National Association of Attorneys General, Director Cordray...more

2/27/2014 - Attorney Generals CFPB Lending Overdraft Fees Pawn Brokers Payday Loans

Pa. Amendments to Installment Sales Statutes Require Attention

Changes to two Pennsylvania statutes governing installment sales will take effect on November 27, 2014, as a result of House Bill 1128, signed into law by Governor Corbett as Act No. 2013-98 (Act 98). Act 98 repeals the...more

2/21/2014 - Automotive Loans Cars Credit Cards Installment Agreements Motor Vehicles Retail Installment Sales Contracts Retailers

New York Attorney General Announces Settlement with Large Payday Lender

On January 24, 2014, New York Attorney General Eric Schneiderman announced that a settlement had been reached with Western Sky Financial, LLC, Cash Call, Inc., WS Funding, LLC, and their principals for alleged violations of...more

2/17/2014 - Interest Rates Lenders Payday Loans Predatory Lending Settlement Usury

CFPB denies payday lender’s petition to modify or set aside CID

The CFPB has issued an order denying the petition filed by CheckSmart Financial Company in September 2013 to modify or set aside a civil investigative demand (CID) it received from the CFPB. ...more

1/28/2014 - CFPA CFPB Fair Lending Investigations Payday Loans Predatory Lending

Tribal Sovereign Immunity Blocks Payday Lending Enforcement Action, Calif. Appellate Court Rules

In a state enforcement action alleging violations of California’s lending law and seeking to enjoin continued lending to state residents, a California Court of Appeal has ruled that tribal sovereign immunity shielded the two...more

1/28/2014 - Enforcement Actions Payday Loans Sovereign Immunity Tribal Governments Tribal Lands

Justice Department, U.S. Attorney, N.C. Attorney General Sue over Reverse Redlining by Auto Dealers

The U.S. Department of Justice (DOJ), the U.S. Attorney’s Office, and the North Carolina Attorney General filed a complaint last week against two corporations that own two “buy here, pay here” used car dealerships, as well as...more

1/21/2014 - Car Dealerships DOJ ECOA Unfair or Deceptive Trade Practices

DOJ lawsuit sends warning to banks dealing with online payday lenders, third-party payment processors, other targeted companies

Last month, the CFPB filed its first lawsuit against companies involved in online payday lending. The lawsuit against CashCall and several related companies that funded, purchased, serviced and collected online payday loans...more

1/21/2014 - Banks CFPB Compliance DOJ Internet Lenders Payday Loans Payment Processors Third-Party Risk UDAAP

DOJ Hits First Bank Target in ‘Operation Choke Point’

Last week, the U.S. Department of Justice (DOJ) filed a lengthy complaint and consent order in a lawsuit against Four Oaks Bank & Trust Company. The DOJ action is the first lawsuit (and settlement) under "Operation Choke...more

1/20/2014 - Banking Sector CashCall DOJ EFTA Fair Lending Payday Loans Payment Processors

FTC Settles Nine Auto Dealer Deceptive Advertising Cases

The Federal Trade Commission announced last week that it had entered into proposed consent orders with nine auto dealers in six states that were charged with deceptive advertising in violation of Section 5 of the FTC Act....more

1/15/2014 - Advertising Car Dealerships CLA False Advertising FTC Regulation M Regulation Z TILA

CFPB bootstraps purported state law violations into attack on online payday lending companies

The CFPB has broken new ground in an attack in Massachusetts federal court against CashCall, several related companies and their principal. The companies funded, purchased, serviced and collected online payday loans made by a...more

12/17/2013 - CashCall CFPB Payday Loans Tribal Corporations UDAAP

Former Colorado regulator and consumer advocate Laura Udis to join CFPB as manager for payday lending program

We have learned that, starting Monday, Laura Udis will join the CFPB as the Payday and Small Dollar Lending Program Manager in Research, Markets and Regulations. Ms. Udis comes to the CFPB from the Consumer Federation of...more

12/16/2013 - Borrowers CFPB Consumer Lenders Credit Agreements Debt Collection Debt Settlement Services Debtor-Creditor Interest Rates Lenders Payday Loans Usury

Payday lender files petition to modify or set aside CID

The CFPB recently posted to its website a petition filed by Checksmart Financial Company to modify or set aside a civil investigative demand it received from the Bureau. ...more

12/10/2013 - CFPB CID Payday Loans

CFPB Issues Aggressive Rulemaking Agenda

The Consumer Financial Protection Bureau’s recently released fall 2013 rulemaking agenda portends aggressive rulemaking by the Bureau in 2014. With most of the rulemaking mandated by the Dodd-Frank Act now completed,...more

12/6/2013 - CFPB Compliance Dodd-Frank Enforcement Mortgages

New York Payday Loan Crackdown Continues as DFS Subpoenas 16 Lead Generators

The New York Department of Financial Services (DFS) opened a new front in its campaign against the payday lending industry by subpoenaing 16 online lead generation firms that allegedly collected and sold consumers’...more

12/4/2013 - Compliance Department of Financial Services Internet Lenders Payday Loans

New York Attorney General Announces Settlement with Debt Collector of Payday Loans

A settlement with the operator of five Buffalo-area debt collection companies announced on November 21, 2013, by New York Attorney General Eric T. Schneiderman marks the latest chapter in the Attorney General's targeting of...more

12/2/2013 - Attorney Generals Debt Collection Debt Collectors FDCPA Payday Loans Settlement

OCC and FDIC Follow Through on Threat To Kill Deposit Advance Loans

The Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) have carried out their threats in their proposed guidance to kill deposit advance loans. On November 21, 2013, the two...more

12/2/2013 - Banks Deposit Advances FDIC Loans OCC

NACHA Invites Comments on Proposed Rules To Improve ACH Network Quality

NACHA, the organization that administers the Automatic Clearing House (ACH) network, recently announced proposed modifications to its Rules and invited comments on or before January 13, 2014. While much of what NACHA proposes...more

11/26/2013 - Borrowers Clearing Agencies NACHA

ACH network on CFPB radar screen

The CFPB could soon be joining the efforts of other federal regulators and New York authorities to deny ACH network access to certain online payday lenders and other businesses deemed to present risks to consumers. In remarks...more

11/26/2013 - CFPB Clearing Agencies Compliance

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