John L. Culhane, Jr.

John L. Culhane, Jr.

Ballard Spahr LLP

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FTC Settles First FCRA Risk-Based Pricing Notice Enforcement Action

The Federal Trade Commission recently announced the settlement of its first enforcement action for alleged violations of the Fair Credit Reporting Act (FCRA) risk-based pricing rule (Rule). The settlement demonstrates that...more

12/24/2013 - Compliance Enforcement Enforcement Actions FCRA FTC Risk-Based Approaches

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

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

CFPB issues warning on furnisher’s duty to investigate disputes

The CFPB has issued a bulletin to companies that furnish information to consumer reporting agencies (CRA) reminding them of their obligation under the Fair Credit Reporting Act (FCRA) to investigate consumer disputes...more

9/5/2013 - CFPB Compliance Duty of Care FCRA Investigations Reporting Requirements Required Documentation

New federal student loan rates create TILA compliance challenges

Last week, in a move intended to lower interest rates on federal student loans, the U.S. House of Representatives passed the Bipartisan Student Loan Certainty Act, which had previously been passed by the Senate....more

8/7/2013 - CFPB Compliance New Legislation Student Loans TILA

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

CFPB Targets Debt Collection in New UDAAP Bulletins, Complaint System, Consumer Action Letters

The Consumer Financial Protection Bureau made clear that debt collection continues to be a major focus by issuing two new bulletins and five action letters for consumers to use when responding to debt collectors....more

7/11/2013 - CFPB Compliance Consumer Complaint System Debt Debt Collection Dodd-Frank FDCPA Harassment UDAAP

Oklahoma Enacts Private Student Loan Requirements

Oklahoma has enacted new requirements for private student loans that become effective on July 1, 2013. The requirements are set forth in the Oklahoma Private Student Loan Transparency Act, a part of House Bill No. 1829....more

6/24/2013 - Compliance Lenders New Legislation Private Student Loans Student Loans

CFPB Issues Guidance on Indirect Auto Lending ECOA Compliance

The Consumer Financial Protection Bureau has issued guidance on fair lending compliance for indirect auto lenders. The guidance targets the practice of “dealer markups.” This practice involves an auto dealer charging the...more

3/22/2013 - Automotive Industry Car Dealerships CFPB Compliance ECOA Fair Lending Financing

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