Jeremy T. Rosenblum

Jeremy T. Rosenblum

Ballard Spahr LLP

Contact  |  View Bio  |  RSS

Latest Publications

Share:

New York Grand Jury Indicts 12 Online Payday Lenders and 3 Individuals

In a shot across the bow of online payday lenders who allegedly disregard state law where their borrowers reside, a New York County grand jury recently voted a criminal usury and conspiracy indictment against 12 companies...more

8/15/2014 - Conspiracies Grand Juries Lenders Payday Loans Usury

Lender Violated EFTA Prohibition on Conditioning Loans on Electronic Payments, Calif. Federal Court Rules

A California federal court recently ruled that a lender violated the Electronic Fund Transfer Act (EFTA) prohibition on “condition[ing] the extension of credit” on a borrower’s repayment “by means of preauthorized electronic...more

8/6/2014 - EFTA Electronic Fund Transfer Act FTC Loans

CFPB releases more overdraft program data as a prelude to likely rulemaking

The CFPB moved closer to likely rulemaking on overdraft programs with the release late last week of a new report entitled “Data Point: Checking account overdraft.” The report is based on account-level and...more

8/4/2014 - Banks CFPB Checking Accounts FDIC Information Reports OCC Overdraft Fees Regulation E Rulemaking Process

FDIC Withdraws List of ‘Risky’ Businesses

In an unexpected move earlier this week, the FDIC issued a Financial Institution Letter (FIL) announcing that it was withdrawing the list of “risky” merchant categories that was included in prior guidance on account...more

8/1/2014 - Choke Point Enforcement FDIC Money Transfer Payday Loans Strategic Enforcement Plan TPPPs

FDIC withdraws list of “risky” businesses alleged to be targeted in “Operation Choke Point”

In an unexpected move earlier this week, the FDIC issued a Financial Institution Letter announcing that it was withdrawing the list of “risky” merchant categories that was included in prior guidance on account relationships...more

8/1/2014 - Compliance Enforcement Enforcement Actions FDIC Money Transfer Payday Loans

Federal district court grants CFPB petition to enforce CIDs issued to tribal lenders

A California federal court recently issued an order granting the CFPB’s petition to enforce its civil investigative demands (CIDs) issued to three tribally-affiliated payday lenders. However, the court also granted the...more

7/29/2014 - CFPA CFPB CID Payday Loans Tribal Loans

House to hold hearings on “Operation Choke Point”

Two House committees have scheduled hearings this week on “Operation Choke Point,” the coordinated federal multiagency enforcement initiative targeting banks serving online payday lenders and other companies that have raised...more

7/15/2014 - Banks Choke Point Congressional Investigations & Hearings Enforcement Legislative Agendas Legislative Committees Payday Loans

CFPB obtains $10 million of relief for payday lender’s collection calls

Yesterday, the CFPB and ACE Cash Express issued press releases announcing that ACE has entered into a consent order with the CFPB. The consent order addresses ACE’s collection practices and requires ACE to pay $5 million in...more

7/11/2014 - CFPB Debt Collection Payday Loans

‘Operation Choke Point’ under Fire

"Operation Choke Point," the coordinated multiagency federal effort to choke off banking services to alleged fraudsters (according to its defenders) or politically unpopular industries (according to its detractors), has come...more

6/13/2014 - ACH Payments Administrative Procedure Act Banks CFPB Choke Point Community Financial Services Association DOJ FDIC Fraud OCC Payday Loans

CFPB replies to tribally-affiliated lenders’ opposition to CIDs

Last Friday, the CFPB replied to the arguments made by three tribally-affiliated payday lenders in opposition to the CFPB’s petition in California federal court seeking to enforce the civil investigative demands (CIDs) issued...more

4/29/2014 - CFPB CID Payday Loans Tribal Loans

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

85 Results
|
View per page
Page: of 4