Jeremy T. Rosenblum

Jeremy T. Rosenblum

Ballard Spahr LLP

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Treasury Department Seeks Information on Online Marketplace Lending

The U.S. Department of the Treasury has issued a request for information (RFI) regarding online marketplace lending. The RFI reflects the Treasury Department’s recognition that online marketplace lending “is a rapidly...more

7/21/2015 - CFPB Dodd-Frank Financial Services Industry Lending Loans Online Marketplace Lending Popular Request For Information U.S. Treasury

32 Democratic senators call for strong payday lending rules

A group of 32 Democratic U.S. senators sent a letter to Director Cordray last week regarding the CFPB’s efforts to address payday lending in which they urged him “to issue the strongest possible rules to end the damaging...more

6/9/2015 - Ability-to-Repay CFPB Legislative Agendas NPRM Payday Loans Richard Cordray

The CFPB’s contemplated payday/title/high-cost lending proposals: our thoughts on collection practice limits

This is the last of a series of blog posts in which we share our reactions to the CFPB’s contemplated proposals taking aim at payday (and other small-dollar, high-rate) loans (“Covered Loans”). In this blog post, we share our...more

4/7/2015 - Ability-to-Repay CFPB Consumer Financial Products Consumer Lenders Debt Collection Payday Loans Proposed Regulation Title Loans

Some issues for “longer-term” loans under the CFPB’s contemplated payday/title/high-cost lending proposals

In this blog post, we share our thoughts on the 36% “all-in” rate trigger and restrictions for loans considered to be “longer-term” under the CFPB’s contemplated proposals taking aim at payday (and other small-dollar,...more

4/6/2015 - Ability-to-Repay CFPB Consumer Financial Products Consumer Lenders Payday Loans Proposed Regulation Title Loans

Some issues for “short-term” loans under the CFPB’s contemplated payday/title/high-cost lending proposals

In this blog post, we share our thoughts on how the CFPB’s contemplated proposals taking aim at payday (and other small-dollar, high-rate) loans (“Covered Loans”) will impact “short-term” Covered Loans and the flaws we see in...more

4/3/2015 - CFPB Consumer Financial Products Consumer Lenders Payday Loans Proposed Regulation Title Loans

The CFPB’s contemplated payday/title/high-cost lending proposals: our initial reactions

Last Friday, we posted a summary of the contemplated CFPB proposals taking aim at payday (and other small-dollar, high-rate) loans (“Covered Loans”). In this blog post, we share our thoughts on the CFPB’s grounds for the...more

4/2/2015 - CFPB Consumer Financial Products Consumer Lenders Dodd-Frank Payday Loans Popular Proposed Regulation Title Loans

CFPB shows its hand on payday (and title and longer-term high-rate) lending

The CFPB has moved a step closer to issuing payday loan rules by releasing a press release, factsheet and outline of the proposals it is considering in preparation for convening a small business review panel required by the...more

3/30/2015 - ACH Payments CFPB Consumer Lenders Dodd-Frank Payday Loans Title Loans

CFPB encourages comments on prepaid card proposal

Kelly Cochran, CFPB Assistant Director for Regulations, addressed the CFPB’s prepaid card rulemaking in a January 12 presentation to the American Bar Association Consumer Financial Services Committee in New Orleans. She...more

1/13/2015 - American Bar Association Banking Sector CFPB Consumer Financial Products Prepaid Payment Products Proposed Regulation

CFPB Director Cordray Issues Warning to Bankers

Director Cordray’s remarks to the Clearing House Thursday should unsettle bankers and payday lenders alike. In his talk, Director Cordray challenged bankers to bow to the inevitable. He suggested that sooner, rather than...more

11/24/2014 - Banking Sector Banks CFPB Choke Point EFTA NACHA Payday Loans Popular Richard Cordray TILA

CFPB Proposes Sweeping Changes for Prepaid Cards

The Consumer Financial Protection Bureau has issued an 870-page proposal for prepaid cards (including 156 pages of actual proposed rules) that mandates new disclosures, error resolution procedures, consumer liability limits...more

11/14/2014 - CFPB Prepaid Payment Products Proposed Regulation

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

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

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 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

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

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

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

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