John L. Culhane, Jr.

John L. Culhane, Jr.

Ballard Spahr LLP

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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

Department of Education proposal on campus financial products expected in July

We recently commented that financial institutions offering financial products to college students, including debit or prepaid cards, under agreements with colleges should be planning now for the possible advent of new...more

6/24/2014 - Colleges Debit Cards Disclosure Requirements DOE Financial Products Prepaid Payment Products Students Title IV Universities

W.Va. Requires Time-Barred Debt Disclosures in ‘Initial Written Communication’

The West Virginia Legislature recently passed H.B. 4360, which amended Section 46A-2-128 of the West Virginia Code, that defines what constitutes unfair or unconscionable debt collection activities. The amendments are...more

4/17/2014 - Debt Debt Collection Disclosure Requirements UDAAP

CFPB’s hand seen in student loan bill

Four Senate Democrats (Senators Boxer, Warren, Durbin and Reed) recently introduced a bill entitled the “Student Loan Borrower Bill of Rights.” On March 1, 2014, the CFPB will begin overseeing servicers of federal and private...more

12/19/2013 - Arbitration CFPB Disclosure Requirements Loan Servicing Proposed Legislation Student Loans TILA

California Enacts New Website Disclosure Requirements

A new California law taking effect on January 1, 2014, will require any operator of a website or online service that collects personally identifiable information on state residents to include new do-not-track disclosures in...more

10/14/2013 - Disclosure Requirements Do Not Track Jerry Brown Privacy Laws Websites

New York Proposes Far-Reaching Debt Collection Regulations

The New York Department of Financial Services (DFS) has proposed new regulations that would impose significant disclosure and other requirements on persons engaged in the collection of consumer debts....more

8/13/2013 - Debt Debt Collection Disclosure Requirements FDCPA Proposed Regulation

FTC Retains Door-to-Door Sales Rule but Proposes Higher Exemption Amount

The Federal Trade Commission recently released its decision to retain its rule requiring disclosure of a buyer’s right to cancel door-to-door sales of consumer goods and services (Cooling-Off Rule)....more

12/28/2012 - Cooling-Off Rule Disclosure Requirements Door-to-Door Sales FTC

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