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Debt Consumer Financial Protection Bureau (CFPB)

Sheppard Mullin Richter & Hampton LLP

CFPB Targets Medical and Rental Debt Collection in 2024 Annual Report

On September 5, the CFPB issued its annual report on debt collection practices, detailing the Bureau’s efforts to enforce the Fair Debt Collection Practices Act (FDCPA). This year’s report focuses on improper practices in the...more

Ballard Spahr LLP

CFPB: Most debt collection complaints in 2023 were attempts to collect debts not owed

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The most frequent consumer debt collection complaints filed with the CFPB in 2023 were attempts to collect debts that actually were not owed, the bureau said in its annual Fair Debt Collection Practices Act report....more

McGlinchey Stafford

Credit, Tips, Obligation to Pay: CFPB Proposed Interpretive Rule Seeks to Clarify Earned Wage Access and Regulation Z

McGlinchey Stafford on

On July 18, 2024, the Consumer Financial Protection Bureau (CFPB) issued notice of a proposed interpretive rule (Rule) that walks back a prior 2020 Advisory Opinion on the manner in which Regulation Z defines “credit.” The...more

Ballard Spahr LLP

Consumer Finance Monitor Podcast Episode: Should Medical Debt Be Included in Creditworthiness Measures?

Ballard Spahr LLP on

The CFPB and state regulators and legislators have medical debt in their crosshairs. In this episode, we’re joined by Chris Eastman, CEO of the Pendrick Group, a Cerberus portfolio company that specializes in financial...more

Davis Wright Tremaine LLP

CFPB Takes Aim at Earned Wage Access Products as Regulated Loans

The Consumer Financial Protection Bureau (CFPB) proposed an interpretive rule that would extend Truth in Lending Act (TILA) and Regulation Z (Reg Z) compliance requirements to many existing earned wage access (EWA) products....more

Nelson Mullins Riley & Scarborough LLP

Who is Paying Who: The Employee or the Employer?

Since 2022, the Consumer Financial Protection Bureau (CFPB) has a stated priority of “protecting employees and their rights through conducting reports, inquiries, and issuing requirements for employers.” In July 2024, the...more

Morrison & Foerster LLP

Earned Wage Access Products would be “Credit” under CFPB Proposed Interpretive Rule

On July 18, 2024, the Consumer Financial Protection Bureau (CFPB) issued a proposed interpretive rule on earned wage access (EWA) products (“Proposed Interpretive Rule”) that, if finalized, would clarify that EWA products are...more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - July 2024 # 3

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Goodwin

CFPB Proposes Rule to Ban Medical Debt from Credit Reports

Goodwin on

Earlier this month, the Consumer Financial Protection Bureau (CFPB) issued a proposed rule to amend Regulation V, which implements the Fair Credit Reporting Act (FCRA), as to medical information and debt. This proposed rule...more

McGlinchey Stafford

NJ District Court Underscores Limits of “Safe Harbor” Protection Under Regulation F

McGlinchey Stafford on

On May 7, 2024, the United States District Court for the District of New Jersey issued a decision holding that the use by a debt collector of the Model Form validation notice under Regulation F does not guarantee compliance...more

Troutman Pepper

Eleventh Circuit Declines to Issue Brightline Rule that Legal Disputes are Not Actionable Under FCRA Instead Finding That Disputes...

Troutman Pepper on

In Holden v. Holiday Inn Club Vacations Inc., the U.S. Court of Appeals for the Eleventh Circuit recently upheld a consolidated district court ruling granting summary judgment for the defendant furnisher in two Fair Credit...more

Troutman Pepper

A Look at Consumer Reporting in 2023, and What's to Come

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The legal landscape of consumer reporting continues to evolve with courts, federal regulators and state legislatures all playing roles in shaping this area of the law. Originally published in Law360 - January 9, 2024....more

Troutman Pepper

CFPB Amicus Brief Supports FDCPA Claim for Unknowing Stay Violation

Troutman Pepper on

On January 2, the Consumer Financial Protection Bureau (CFPB) filed an amicus curiae brief urging the U.S. Court of Appeals for the First Circuit to reverse a district court’s decision finding that a debt collector lacked the...more

Ballard Spahr LLP

CFPB files amicus briefs in FDCPA case and also files amicus brief in FCRA case jointly with FTC

Ballard Spahr LLP on

The CFPB recently filed two amicus briefs, one in a First Circuit case involving the Fair Debt Collection Practices Act (FDCPA) and the other, which was filed jointly with the Federal Trade Commission, in a Fourth Circuit...more

Ballard Spahr LLP

Democratic Senators urge continued CFPB scrutiny of buy-now-pay-later products

Ballard Spahr LLP on

Democratic Senator Sherrod Brown, who chairs the Senate Banking Committee, and Democratic committee members Raphael Warnock and John Fetterman, have sent a letter to Director Chopra urging the CFPB to “continue focusing on”...more

Ballard Spahr LLP

CBA concludes blog post series countering CFPB information about CARD Act report

Ballard Spahr LLP on

The Consumer Bankers Association has issued the third and fourth blog posts in its four-part “Facts Matter” blog series on how the CFPB’s public statements can mislead market observers by painting a picture of the credit...more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - December 2023 # 3

Troutman Pepper on

To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Troutman Pepper

CFPB Shuts Down Medical Debt Collector for Attempting to Collect Unverified Debt

Troutman Pepper on

On December 15, the Consumer Financial Protection Bureau (CFPB) announced it had reached a settlement with medical debt collector Commonwealth Financial Systems, Inc. (Commonwealth) in its lawsuit over alleged illegal debt...more

Ballard Spahr LLP

CFPB settles claims against operator of training program arising out of income share agreements

Ballard Spahr LLP on

The CFPB recently announced the settlement of a bankruptcy court adversary proceeding filed jointly with the Attorneys General of 11 states against Prehired, LLC (Prehired) and two affiliated companies (Prehired Affiliates)...more

Troutman Pepper

Medical Debt Under the Microscope: Insights from the CFPB’s 2022 FDCPA Report

Troutman Pepper on

On November 16, the Consumer Financial Protection Bureau (CFPB or Bureau) released its Fair Debt Collection Practices Act (FDCPA) Annual Report detailing the CFPB’s 2022 activities related to debt collection practices. This...more

Jackson Lewis P.C.

Training Repayment Agreements Remain Under Federal Scrutiny

Jackson Lewis P.C. on

Training repayment agreements (TRA) are a tool for retaining employees after they received employer-paid training. Generally, a TRA requires an employee to repay an employer for the costs of training if the employee leaves...more

Sheppard Mullin Richter & Hampton LLP

CFPB Initiates FCRA Rulemaking on Medical Debt and Data Brokers

On September 21, the CFPB announced that it has initiated a rulemaking process under the Fair Credit Reporting Act (“FCRA”) that would remove medical bills from consumer credit reports. The CFPB also published an Outline...more

Bradley Arant Boult Cummings LLP

Questions to Consider as Regulators Increase Scrutiny of Medical Debt

Over the last year and a half, the Consumer Financial Protection Bureau (CFPB) has become increasingly interested in the origination, servicing, and collection of medical debt. The CFPB alone has published several pieces of...more

Husch Blackwell LLP

CFPB Spotlights Harms of Employer-Driven Debt

Husch Blackwell LLP on

On July 20, 2023, the CFPB published a report concerning the risks posed to consumers by employer-driven debt. Employer-driven debt is any form of financing arrangement where an employer extends credit or a lease to an...more

Wiley Rein LLP

Wiley Consumer Protection Download (July 24, 2023)

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Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more

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