John L. Culhane, Jr.

John L. Culhane, Jr.

Ballard Spahr LLP

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The CFPB Announces Final Diversity Standards under Dodd-Frank Section 342 Are Completed

On April 29, 2015, the Office of Minority and Women Inclusion (OMWI) of the Consumer Financial Protection Bureau (CFPB or Bureau) released its third Annual Report for 2014, as mandated by Section 342(e) of the Dodd-Frank Act...more

5/6/2015 - CFPB Diversity Dodd-Frank Federal Contractors OMWI

CFPB to hold May 14 field hearing on student debt

The CFPB has announced that on May 14, 2015, it will hold a field hearing in Milwaukee on student debt. Similar to other field hearings, Director Cordray will give remarks and witnesses will include members of consumer...more

4/30/2015 - Administrative Hearings CFPB Consumer Lenders Student Loans Students

Cordray remarks signal continued CFPB attention to student loan servicing and campus financial products

Student loan servicers and providers of campus financial product were the focus of remarks given yesterday by Director Cordray at the Ohio College Presidents’ Conference. Director Cordray stated that the CFPB estimates that...more

4/24/2015 - CFPB Colleges Consumer Financial Products Loan Servicing Richard Cordray Student Loans Universities

FTC Issues 2014 Complaints Report

The Federal Trade Commission received more than 2.5 million consumer complaints in 2014, according to its newly released Consumer Sentinel Network Data Book. The annual report provides national and state-by-state data on...more

3/13/2015 - Annual Reports CFPB Consumer Complaint System FTC

CFPB seeks information from industry on student loan modification options and issues guidance on private student loans with ...

As a follow up to a January 2014 meeting with private student loan lenders and servicers convened by Director Cordray and Education Secretary Arne Duncan, the CFPB sent letters last week to certain “market participants”...more

2/3/2015 - CFPB FDIC Federal Reserve Lenders Loan Servicer Market Participants NCUA OCC Private Student Loans Student Loans

FTC continues to press concerns about credit report accuracy in follow-up report

A follow-up report on credit report accuracy issued this week by the Federal Trade Commission is likely to be cited by the CFPB as additional support for the CFPB’s concerns about inaccurate credit reporting. In December...more

1/23/2015 - CFPB Credit Reporting Agencies Credit Reports FTC Reporting Requirements

CFPB proposes scorecard for colleges seeking to partner with financial institutions

The CFPB has issued a request for information (RFI) in which it seeks comments on a draft “Safe Student Account Scorecard” to be used by colleges and universities to obtain information from prospective financial institution...more

1/15/2015 - CFPB Colleges Consumer Financial Products Financial Institutions Request For Information Students Universities

CFPB endorses MLA expansion

In an effort to build support for the Department of Defense’s proposal to significantly expand Military Loan Act coverage, the CFPB has released a report entitled “The extension of high-cost credit to servicemembers and their...more

12/30/2014 - Banking Sector Banks CFPB DOD FDIC Military Lending Act Military Service Members

CFPB report highlights inadequate disclosure of campus financial products

In its fifth annual report on college credit card agreements, the CFPB takes financial institutions as well as colleges and universities to task for failing to adequately disclose their marketing agreements for campus...more

12/19/2014 - CARD Act CFPB Colleges Credit Cards Disclosure Requirements Marketing Universities

CFPB requires credit bureaus to identify furnishers and industries with highest dispute rates and issues study of collections...

In conjunction with its field hearing today on medical debt collection, the CFPB released a study that “describes characteristics of the medical and non-medical collections tradelines on consumers’ credit reports and the...more

12/12/2014 - CFPB Credit Reporting Agencies Credit Reports Debt Collection

CFPB to hold Dec.11th field hearing on medical debt collection

The CFPB has announced that it will hold a field hearing on medical debt collection in Oklahoma City, OK on December 11. The hearing will include remarks from Director Cordray and testimony from consumer groups, industry...more

12/2/2014 - Administrative Hearings CFPB Debt Collection Healthcare Costs Richard Cordray

AFSA vehicle sales finance study finds significant flaws in CFPB disparate impact methodology and approach

A study of indirect auto financing commissioned by the American Financial Services Association found that the CFPB’s proxy methodology for measuring disparities in auto dealer reserve is “conceptually flawed in its...more

11/25/2014 - Auto Manufacturers Automotive Industry Automotive Loans Car Dealerships CFPB Retail Installment Sales Contracts

CFPB highlights alleged credit reporting errors relating to discharged student loans of disabled veterans

In a new blog post, the CFPB provides credit reporting advice to service-disabled veterans who take advantage of federal student loan forgiveness available from the Department of Education for veterans who receive a 100...more

11/20/2014 - CFPB Credit Reports Department of Education Department of Veterans Affairs Disability Dischargeable Debts Loan Servicer Student Loans Veterans

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 Student Loan Ombudsman Files Third Annual Report Highlighting Bureau’s Hot Button Issues in Student Lending

The CFPB released its third Annual Report of the Student Loan Ombudsman, Rohit Chopra, discussing complaints received by the CFPB about private student loans and the lessons drawn by the Ombudsman from those complaints....more

10/21/2014 - CFPB Fair Lending Information Reports Ombudsman Student Loans Students

CFPB Releases Report on Fair Credit Exams and White Paper on Proxy Methodology

Along with its proposed larger participant rule for the auto financing market, the Consumer Financial Protection Bureau issued a special edition of Supervisory Highlights (the "report") describing its fair credit supervisory...more

9/24/2014 - Automotive Industry Automotive Loans Car Dealerships CFPB Debt Buyers Larger Participant

CFPB Proposes Rule To Supervise Nonbank Auto Finance Companies

The Consumer Financial Protection Bureau has issued a proposal to supervise nonbank companies that qualify as “larger participants of a market for automobile financing.” Comments on the proposal will be due 60 days after the...more

9/19/2014 - Automotive Industry Automotive Loans Banks CFPB Nonbank Firms

Brookings student loan study updated; CBA launches website to dispel student loan myths

We previously wrote about the June 2014 Brookings Institution report which suggested that charges coming from various quarters, including the CFPB, that student loan debt is causing young adults to postpone home ownership are...more

9/12/2014 - CFPB Student Loans

CFPB announces higher education memorandum of understanding

The CFPB announced that it has entered into a “Joint Higher Education Memorandum of Understanding” with the Departments of Veterans Affairs (VA), Defense (DOD), and Education (ED) as part of a joint effort by the agencies “to...more

8/29/2014 - CFPB Department of Education Department of Veterans Affairs DOD For Profit Colleges For Profit Education Memorandum of Understanding

CFPB files amicus brief in Ninth Circuit FDCPA case

The CFPB, together with the FTC, has filed an amicus brief in Hernandez v. Williams, Zinman & Parham, P.C., a Fair Debt Collection Practices Act case on appeal to the U.S. Court of Appeals for the Ninth Circuit. ...more

8/25/2014 - CFPB Debt Debt Collection FDCPA FTC

CFPB calls out banks for not publicly disclosing campus financial product marketing agreements

According to a new blog post about “secret banking contracts” by Rohit Chopra, the CFPB’s Student Loan Ombudsman, the CFPB is sending letters to colleges and universities “to make sure they know that their bank partner has...more

8/8/2014 - Banks CFPB Colleges Disclosure Requirements Enforcement Student Loans Universities

CFPB continues to solicit comments on proposed debt collection survey

The CFPB published a notice in the Federal Register today announcing that it will continue to take comments until August 22, 2014 on its plans to seek approval from the Office of Management and Budget “to conduct a mail...more

7/24/2014 - American Bankers Association CFPB Debt Collection OMB

More on the debate over the impact of student loan debt on home ownership

We recently wrote about a new Brookings Institution report which suggested that charges coming from various quarters, including the CFPB, that student loan debt is causing young adults to postpone home ownership are...more

7/24/2014 - CFPB Debt Student Loans

New studies challenge CFPB claims that student loan debt is discouraging homeownership

The charge that student loan debt is causing young adults to postpone home ownership has come from various quarters, including the CFPB. However, two new studies, one the subject of an article released earlier this year and...more

6/27/2014 - CFPB Debt Student Loans

Senate holds hearings on student loans

Last Wednesday, the Senate Budget Committee and the Senate Banking Committee held separate hearings about student loans. Interestingly, the CFPB was represented in only one of the hearings. The Senate Budget Committee...more

6/9/2014 - CFPB Predatory Lending Student Loans

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