Jeremy T. Rosenblum

Jeremy T. Rosenblum

Ballard Spahr LLP

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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 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

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

New York Proposes New Force-Placed Insurance Regulations

The New York Department of Financial Services (DFS) recently issued proposed force-placed insurance regulations to reduce premiums and eliminate kickbacks that it claims are pervasive in the industry. The regulations will...more

9/24/2013 - Anti-Corruption Compliance Financial Conduct Authority Fraud Kickbacks Premiums Proposed Regulation

CFPB Warns Employers on Required Use of Payroll Cards

The Consumer Financial Protection Bureau has issued a bulletin warning employers that they cannot require employees to receive their wages on payroll cards. The bulletin appears to respond to the explosive growth in the use...more

9/16/2013 - CFPB Compliance EFTA Minimum Wage Payroll Cards Regulation E Wages

New York Takes Aim at Internet Payday Lenders and Other Industry Players

The Cuomo administration, through the New York State Department of Financial Services (DFS), recently announced aggressive enforcement-related activities in an ongoing DFS investigation designed to stop supposedly unlawful...more

8/9/2013 - Compliance FDCPA Financial Services Authority Fraud Internet Investigations NACHA Payday Loans

Democratic Senators write to CFPB about employer use of payroll cards

A New York Times report last month that the office of New York Attorney General Eric Schneiderman has commenced an investigation into the widening practice of employers paying hourly employees through the use of prepaid...more

7/18/2013 - CFPB Compliance DOL Employer Liability Issues Payroll Cards Wage and Hour

FTC Enforcement Action against Debt Collector Ends in Record Settlement

The Federal Trade Commission’s recent announcement that it entered into a record settlement with “the world’s largest debt collection operation” demonstrates that it intends to continue its vigorous enforcement of the Fair...more

7/16/2013 - Compliance Debt Collectors Dodd-Frank Enforcement Actions FDCPA FTC Settlement

OCC and FDIC proposed guidance could effectively ban deposit advance loans

Last Thursday, the Office of the Comptroller of the Currency and Federal Deposit Insurance Corporation proposed guidance on deposit advance loans. The Federal Reserve Board declined to join the OCC and FDIC and instead...more

4/30/2013 - CFPB Compliance Deposit Advances FDIC Loans OCC Proposed Regulation Underwriting

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